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CFR Investigation Team
In 1977, Congress passed the Community Reinvestment Act, requiring banks to demonstrate they were lending in low- and moderate-income neighborhoods. The law was a response to redlining — the real and well-documented practice of banks refusing to extend credit in Black communities.
What the law didn't do was ask why those communities were poor in the first place, or whether extending credit to people who couldn't sustain it was a solution or a trap. The premise was tested at national scale in the 2000s. The results speak for themselves.
And over the next five decades, an entire industry grew up around CRA — one that had less to do with helping communities and everything to do with extracting money from banks under the threat of regulatory action.
Every bank in America receives a CRA rating from federal regulators. The grades work like school: Outstanding, Satisfactory, Needs to Improve, or Substantial Noncompliance. A bad CRA rating can block a bank from opening new branches, launching new products, or — most importantly — merging with other banks.
That last one matters. In the era of banking consolidation, mergers are worth billions. A CRA challenge from a community group can delay or derail a merger entirely. So banks learned to play the game — and they play it willingly, because the cost of compliance is trivial compared to the value of a merger.
The result is a machine with several moving parts. Advocacy organizations pressure banks over their CRA ratings. Banks respond by signing Community Benefits Agreements (CBAs) worth billions on paper, buying Low-Income Housing Tax Credits (LIHTC) that fund housing developments, and making direct contributions to civil rights organizations. The money flows through middlemen to politically connected developers who build projects in low-income neighborhoods — projects that are technically "affordable" but often priced far beyond what the existing community can pay. The developers collect fees. The middlemen collect fees. The banks get regulatory credit. And the neighborhoods get gentrified.
That's the architecture. Here's how each piece works.
The National Community Reinvestment Coalition, or NCRC, is a Washington, DC-based nonprofit with over 700 member organizations and roughly $40 million in annual revenue. NCRC's primary business is positioning itself between banks that need CRA credit and the communities those banks are required to serve.
The most visible product of this arrangement is the Community Benefits Agreement, or CBA. When a large bank announces a merger, NCRC and its member organizations raise concerns (peaceful protests) about the bank's CRA record. The bank negotiates a CBA — a public commitment to "invest" a certain amount in underserved communities over a set number of years. NCRC gets to claim a victory. The bank gets to close its merger.
Since 2016, NCRC has brokered over $620 billion in these agreements — roughly 37 times Chicago's annual budget. Some examples:
A single deal — PNC's acquisition of BBVA — carried a $88 billion commitment. U.S. Bank pledged $100 billion. Huntington pledged $40 billion.
These are enormous numbers. They are also voluntary, non-binding, and unenforceable. No CBA has ever been declared a failure. The "commitments" typically repackage lending and investment the bank was already planning to do, rebranded under the CBA umbrella. But everyone at the negotiating table gets what they came for: the bank gets regulatory clearance, NCRC gets to announce a number, and the member organizations get positioned for funding. NCRC itself is funded in part by the same banks it negotiates with — the groups sitting on one side of the table as community advocates are bankrolled by the institutions on the other side.
CBAs are the handshake. The real money moves through housing.
Congress created the Low-Income Housing Tax Credit in 1986, and it has quietly become the single largest affordable housing program in the country. State agencies award tax credits to housing developers, who sell those credits to banks for upfront cash. The banks get a tax break. They also get CRA credit — which is why they'll pay a premium for credits in the specific low-income neighborhoods where they need regulatory points. The advocacy organizations create the CRA pressure. The banks relieve it by buying tax credits. And the developers who get the projects are, inevitably, the ones with the right connections.
Between CBAs, tax credit investments, and direct charitable contributions to organizations like NCRC, the National Urban League, and Rainbow PUSH, banks have a well-worn menu for buying regulatory peace. The money flows. The middlemen collect. And the communities that justified all of it see remarkably little.
How little? That depends on a two-letter phrase buried in the regulations.
CRA regulations allow banks to receive credit for investments made in low- and moderate-income census tracts, regardless of whether the residents who benefit are themselves low- or moderate-income. Building a $500,000 home in Woodlawn qualifies for CRA credit because Woodlawn is a low-income area — even though most Woodlawn residents can't afford a $500,000 home.
The key phrase is "in or for." GROWTH by NCRC — the affordable housing brand we'll examine in a moment — states its own mission as providing opportunities "in or for low- and moderate-income communities and people." That small conjunction is the gap the entire industry operates in. And NCRC doesn't just negotiate on behalf of communities — it runs its own fund to invest directly.
NCRC also runs its own investment vehicle: the NCRC Housing Rehab Fund, LLC — a Delaware-registered private equity fund with an SEC filing from 2015. Banks invest and receive CRA credit. The fund's consumer-facing brand, GROWTH by NCRC, claims over 1,000 homes across 20 communities.
Its early projects were genuinely affordable. In Columbia, South Carolina, GROWTH partnered with Benedict College to build eight homes starting at $130,000, restricted to buyers earning 80% or less of the area's median income.
Then the fund came to Chicago.
In 2018, the NCRC Housing Rehab Fund purchased a series of vacant lots and foreclosed properties along Evans Avenue in the Woodlawn neighborhood on Chicago's South Side. The lots came from the Cook County Land Bank Authority, most for prices between $1 and $9,000. One was a foreclosure acquired for $50,000.
The local partner for this project was Greenlining Realty USA, a firm founded by Lamell McMorris that partnered with NCRC's GROWTH initiative. In December 2020, a virtual groundbreaking ceremony featured Pete Buttigieg, Al Sharpton, Jesse Jackson, and Martin Luther King III. The project was called Woodlawn Pointe, and it consisted of nine homes — seven new construction and two renovations.
McMorris is not primarily a real estate developer. He is a registered federal lobbyist, the founder of Phase 2 Consulting, and the head of government affairs at the financial firm Edward Jones. He simultaneously serves as Senior Vice Chair of the National Urban League, and holds board positions at the National Action Network and Rainbow PUSH Coalition. In other words, he lobbies financial institutions on behalf of corporate clients while sitting on the boards of organizations that negotiate with those same institutions over CRA compliance.
As of early 2026, Greenlining Realty USA's website lists two employees: McMorris and one other staff member. It lists three projects: Woodlawn Pointe (nine homes), a joint venture with DL3 Realty on Revive 6300, and Druid Hills Pointe — a 43-home development in Birmingham, Alabama. The Birmingham project suggests the Woodlawn playbook is scaling to other cities.
Cook County property records tell the story of what happened next.
6514 S. Evans Avenue: NCRC Housing Rehab Fund purchased this lot from the Cook County Land Bank for $9,000 in August 2018. It sold in January 2022 for $539,000.
6522 S. Evans Avenue: Acquired through a foreclosure sale for $50,000 in November 2018. Sold in June 2021 for $508,000. The buyer resold it in May 2025 for $570,000.
6547 S. Evans Avenue: Purchased from the Land Bank for $4,500 in August 2018. As of the most recent records, this property has not been sold to an individual buyer. NCRC's Washington, DC headquarters remains the mailing address on file.
The median household income in this census tract is $18,983 per year. A $539,000 home requires a household income of roughly $120,000 — more than six times the neighborhood median.
These are not affordable homes. They are market-rate homes built with money earmarked for affordable housing, on land given away for free by a public agency, by a fund that exists because banks need CRA credit. The banks got their credit — and likely a financial return, since the fund is structured as private equity, not charity. NCRC collected management fees. As the developer, McMorris would have collected developer fees, as is standard in any development deal — though the exact terms aren't public because the fund is structured as a private LLC. The neighborhood got nine houses it couldn't afford.
One of the properties renovated as part of Woodlawn Pointe was 742 E. Marquette Road — a house that Lamell McMorris had purchased from his own mother, Bertha McMorris, for $1.
Cook County records tell the rest of the story:
The property was one of the two renovations in Woodlawn Pointe — the nine-home project developed by McMorris's own company, Greenlining Realty USA, using capital from the NCRC Housing Rehab Fund. McMorris still owns the house. It was never sold. The Cook County Assessor currently values it at approximately $200,000.
On Greenlining Realty's website, one section is named the "Bertha McMorris Innovation & Technology Institute" — after his mother.
Nine houses is a small operation. But McMorris's connections open doors to much larger ones.
His two-person firm is a joint venture partner with DL3 Realty, run by developer Leon Walker, on Revive 6300 — a $40-million-plus redevelopment of the former Washington Park National Bank building at 6300 S. Cottage Grove Avenue. The city granted $5 million to the venture. That project stacks New Markets Tax Credits, Opportunity Zone benefits, city grants, and Neighborhood Opportunity Fund dollars. A two-person firm with nine houses to its name is a partner on a deal that stacks every public subsidy in the book.
DL3's own projects show what the unit economics of this system look like at scale.
THRIVE Englewood is a 62-unit, six-story building at 6249 S. Sangamon Street. DL3's marketing materials describe it as "affordable luxury." The project was included in Mayor Lightfoot's $1 billion LIHTC allocation in 2021.
THRIVE Exchange is a mixed-use development in South Shore that won a City of Chicago Invest South/West award. The first phase alone costs $26.3 million for 43 affordable workforce units — funded by $10.2 million in TIF — Tax Increment Financing, which captures future property tax growth within a designated district and diverts it from schools and other taxing bodies into development subsidies — and $10.6 million in LIHTC equity from banks buying tax credits for CRA compliance. That's $10.2 million in direct city subsidy and another $10.6 million in bank investment driven by federal tax credits — over $20 million for 43 apartments, or about $480,000 per unit. City contract records show Thrive Exchange, LLC received an additional $19.5 million from the Department of Planning and Development for the broader multi-phase project.
The units are rent-restricted to households earning 60% of Area Median Income — but AMI is pegged to the metro area, not the neighborhood. HUD's 2025 median family income for the Chicago metro is $119,900. Sixty percent of that is about $72,000 for a family of four. In South Shore, where the median household earns under $30,000, that's not affordable housing for the existing community. It's subsidized housing for people from somewhere else.
If you've noticed the same boxy, five-story apartment buildings appearing in low-income neighborhoods across the country — wood-frame over a concrete podium, vinyl floors, "luxury" amenities — those are almost all LIHTC deals, optimizing for the same subsidy formula from Chicago to Atlanta to Birmingham.
These buildings attract higher-income tenants into low-income areas. Property values rise. Property taxes follow. Existing residents get priced out. The program designed to fight disinvestment has become an engine of gentrification — and the advocacy organizations that pressure banks into funding these projects are, in many cases, the same ones that decry gentrification in their fundraising materials.
Here is what happens: NCRC threatens to challenge a bank's CRA rating — effectively threatening to cry racism — and the bank buys peace through CBAs, LIHTC investments, and direct contributions. That money flows to politically connected developers who build homes and apartments too expensive for the communities the program claims to serve. A lobbyist who sits on three civil rights boards develops his family's property with bank-funded affordable housing money. His two-person firm partners on $40 million deals. His business partner collects $19.5 million city contracts for apartments that cost half a million each in public subsidy. The banks get CRA credit. NCRC collects fees. The neighborhoods get gentrified.
The early GROWTH projects — eight homes in Columbia, South Carolina, sold for $130,000 to families at 80% of area median income — show what the program could be. What it has become is a mechanism for converting regulatory compliance into developer profit, with the aesthetics of social justice layered on top.
Nobody in this system is breaking the law. That's the point.
There is a different model for building wealth in American communities — one with a track record. It's called the American System: investment in infrastructure, education in the sciences and practical trades, and low barriers to enterprise. It was the framework that turned Chicago from a swamp into a rail hub, that reversed the flow of a river, that built the industries and the middle class that came with them.
That path was never taken in Woodlawn, or Englewood, or South Shore. Instead of building productive capacity, the CRA framework asks how to get banks to lend to people who are still poor — and when those people can't sustain the debt, the cycle starts over. The only people who reliably profit are the intermediaries.
The answer to redlining was never to force banks to make loans in neighborhoods where borrowers can't sustain them. It was to build an economy where those borrowers don't need a government mandate to qualify.
Federal agencies and regulations
NCRC and community benefits agreements
Property records and public data
Developer and project pages
Board positions and lobbying
Property records cited in this article are from the Cook County Assessor's Office and the Cook County open data portal. Contract data is from the City of Chicago's open data portal. SEC filings are from EDGAR. All records are publicly available.
This is the first article in the series "The Race-Hustle Industrial Complex."