The New York State Department of Financial Services ("NYDFS") stated that banking institutions that are subject to the New York Community Reinvestment Act ("CRA") may receive CRA credit for financing climate resiliency projects in low- and moderate-income ("LMI") communities.
In an industry letter, NYDFS listed the following projects, among others, that would qualify for credit in CRA examinations:
renewable energy, energy efficiency and water conservation equipment to reduce utility payments for LMI tenants in affordable housing (e.g., solar panels and improving building envelope insulation);
community solar projects;
battery storage projects in LMI communities with high flood and/or wind risks to reduce power loss; and
flood resilience through building elevation.
NYDFS explained that, as climate change disproportionately affects LMI communities, which in turn have a higher percentage of minority populations, the banks would be acting to meet the credit needs of these communities.