On April 8, BPI submitted a comment letter to the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation responding to the joint agency proposal to revise the Community Reinvestment Act. The letter expresses support for the broader goals of modernizing the CRA, but notes that the proposal contains some matters which require further attention. These include: (i) a lack of necessary data to quantify the proposal, (ii) imposing unusual data collection, (iii) record keeping and reporting burdens on banks, (iv) understating the value to communities of nonrecorded balance sheet activities, (v) subjecting consumer lending to mandatory evaluations, (vi) requiring a substantial amount of CRA performance tests, (vii) inaccuracy of the term “retail domestic deposit,” and (viii) lack of adaptability in bank business models.
To read the full letter, click on the download button below.
