The Greenlining Institute

08/19/2025 | News release | Distributed by Public on 08/19/2025 12:16

Comment Letter: CRA Regulaltions

Comment Letter: CRA Regulaltions

Comment Letters and Testimony Economic Equity
Rawan Elhalaby, Erica Plasencia, Rami Ibrahim, Monica Palmeira August 19, 2025

Rawan Elhalaby

Director for Economic Equity

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Rawan Elhalaby

Director for Economic Equity

Rawan Elhalaby (she/her/hers) is the Associate Director of Economic Equity at the Greenlining Institute where she oversees bank accountability efforts using the Community Reinvestment Act. As the daughter of working class refugees, Rawan is all too familiar with the obstacles to achieving self-sufficiency in the United States for low-income and immigrant families. As such, she has spent her career addressing these obstacles at Greenlining and one-on-one with recently arrived refugees from Iraq, Somalia, Syria, and Afghanistan (among others) to San Diego at the International Rescue Committee. She has also worked as a policy consultant to the Consumer Financial Protection Bureau, the County of San Diego, the Western Regional Advocacy Project, and the Dellums Institute for Social Justice. Rawan holds a degree in Political Science from San Diego State University and a Master of Public Policy from UC Berkeley's Goldman School of Public Policy.

Economic Equity Policy Staff

Erica Plasencia

Sr. Program Manager for Economic Equity

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Erica Plasencia

Sr. Program Manager for Economic Equity

Erica Plasencia (she/her/ella) is a first-generation daughter of Mexican immigrants. She grew up in a small rural town in Northern California, where she experienced the clear impacts of limited access to resources and education, and its implications on social and economic mobility for communities of color. As the Program Manager for Economic Equity at Greenlining, Erica leads bank accountability efforts at the federal level using the Community Reinvestment Act, an anti-redlining law that obligates banks to serve the needs of low and moderate income communities and reinvest in these communities in order to combat the racial wealth gap and segregation. Prior to joining The Greenlining Institute, she worked at California Community Builders where she helped address economic and racial justice issues through community education efforts on redlining and policy advocacy focused on access to homeownership for people of color. In addition to her non profit work, Erica has worked in various higher education settings helping address the Latinx educational pipeline by assisting students with college readiness skills, retention programs, and implementing culturally relevant curriculums. Erica enjoys going home to her mom's home cooked meals, dancing, playing volleyball, and going on hikes with her fiance.

Economic Equity Policy Staff

Rami Ibrahim

Program Manager for Economic Equity

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Rami Ibrahim

Program Manager for Economic Equity

Rami Ibrahim (he/him/his) is the Economic Equity Coordinator team, supporting The Greenlining Institute's vision of economic investment among communities of color and holding financial institutions accountable. As a second-generation Palestinian American, Rami is passionate about ending U.S. destabilization of our homelands and centering refugee and immigrant communities in policies surrounding economic, climate, housing, and health justice. Prior to joining Greenlining, he conducted research pertaining to refugee resettlement and engaged San Diego refugee and immigrant communities in State, County, and City redistricting processes. Rami was born and raised in San Diego, California and received a B.A. in Political Science from UC San Diego. His dream is to continue fighting in coalition with Palestinian youth and elders and marginalized communities throughout the world for our collective liberation.

Economic Equity Policy Staff

Monica Palmeira

Associate Director of Economic Equity

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Monica Palmeira

Associate Director of Economic Equity

Monica Palmeira (she/her/hers) was raised in Eastern North Carolina as a first-generation American in a Portuguese family. Her professional background includes ethnographic research, affordable housing advocacy, climate policy, and community engagement. Prior to joining Greenlining, Monica most recently held positions at the California Public Utilities Commission leading environmental justice initiatives, as well as at the California Governor's Office of Planning and Research - Strategic Growth Council where she spearheaded various outreach and technical assistance programs to support communities in accessing climate-related funding programs. She received a B.A. in International Studies and Public Policy from the University of North Carolina at Chapel Hill and a Master's in Public Administration from the University of Southern California. In her free time, Monica loves spending time with her young son, visiting family back in Portugal, and rediscovering her home state.

Policy Staff Transformative Communities

The Greenlining Institute submitted comments to the OCC, FDIC and Federal Reserve in opposition to the rescission of the 2023 Final CRA rule. Rescinding the 2023 Community Reinvestment Act (CRA) Final Rule will undermine the goals of the CRA and reduce its effectiveness in a new era of financial services, which includes online banking and the lasting impacts of historic and modern redlining.

Greenlining's comments highlight the continued importance of the CRA for LMI communities, the need for CRA modernization, and the critical areas the 2023 CRA Final Rule sought to address and that returning to the 1995 rules will rollback, including: assessment areas for retail lending, improvements around community development investments, community participation and clarity around Special Purpose Credit Programs.

Read the full comment letter here.

Monica Palmeira

Associate Director of Economic Equity

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