CBA Comment Letter on Proposed Interagency Changes to CRA Questions & Answers

Dear sir or madam:

The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the proposal by the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Corporation (FDIC) (Collectively, the Agencies) to clarify their Interagency Questions and Answers (Q&A) regarding the Community Reinvestment Act (CRA). CBA has been actively engaged in CRA and CRA-related activities since its enactment, and is a strong supporter of community development activities by financial institutions and others.

CBA submitted comments and testified at the hearings held in 2010, and we are grateful that some of our issues have led to these proposed Q&A revisions. We believe that several of the proposed changes are beneficial and will be a step in the right direction, and we are appreciative of the thoughtful way the Agencies have addressed these difficult issues. We have some specific comments addressing some of the Q&A, as set forth below. 

To read the full Comment Letter, download the PDF.