Discusses the types of financial institutions that should have reinvestment responsibilities and the geographies where those responsibilities are assessed. Also includes recommendations to improve the services test portion of the CRA and improve the ratings and incentive structure of the CRA.

Testimony presented to the Office of Thrift Supervision opposing Republic Bancorp’s application for a charter conversion from a bank holding company to a savings and loan holding company.  Discusses the impact of the RAL product on lower-income Chicago communities and need to eliminate the refund anticipation loan product or require additional consumer protections.

Testimony before the US House of Representatives Subcommittee on Oversight and Investigations on OTS’s actions to weaken CRA.  Comments offered suggestions to promote improvements to CRA that would increase access to lending, investments, and services in low- and moderate-income markets such as the requiring the continued reporting of small business lending data for mid-sized banks and thrifts.  They also requested that the OTS collect data on new retail accounts opened for low- and moderate-income households; and promoting investment in declining and underserved rural markets.