Comment letter to the Federal Reserve, OCC, and FDIC on the Interagency Q&A Regarding Community Investment

This letter to the Federal Reserve, OCC, and FDIC supports several provisions of the Interagency Q&A Regarding Community Investment. The letter notes several concerns about the Q&A and identifies several areas where CRA needs to be updated.

This letter to the Federal Reserve, OCC, and FDIC supports several provisions of the Interagency Q&A Regarding Community Investment, including additional ways to determine low- and moderate-income status of community development recipients, recognition of nonprofit board service, and clarifications on qualified investments and community development lending. The letter notes concerns about the Q&A's proposed changes to the weights on community development lending. The letter also identifies several areas where CRA needs to be updated, including expanding assessment areas to where an institution has market share, creating a community development test, and making the services test more rigorous.