Commenting on CRA

You have to comment on this one. The consequences are much more extensive than "regulatory burden" or "compliance." The consequences of this rulemaking process will affect your bank's future, including the ability of the bank to open new branches, offer new products and services, and to compete in the increasingly complicated world of finance.

The ANPR poses specific questions, based on information the agencies already have. These questions are among the most important and frequently raised industry concerns. But they aren't necessarily the only things to consider. Approach your comments as creatively as possible. This is the time to open the door to a different way of evaluating CRA performance. Focus on what is needed and what works in your community. Then figure out how that should be evaluated.

To make it easier for you to prepare a comment letter, here are some points to discuss. You don't need to comment on all of these points. One or a few will do. Choose the issues that are most important to your institution and put your energy on them. The most important thing you can do is send in your comments!

Topics for Comment

Compare your most recent CRA exam under the current regulation with the examination under the previous regulation. Discuss which examination did a better job of fairly evaluating your CRA program.
Is the balance between lending, service, and investments appropriate or is too much emphasis put on lending?
Does the current regulation give proper recognition to all of the activities that you think it should?

If not, why not and how could the regulation be changed to improve on this?

What are the three most positive aspects of the current regulation for your bank and why?
What are the three most negative aspects of the current regulation for your bank and why?
How much does your bank spend preparing for a CRA examination? How much of this is spent on data collection and reporting?
What is the most effective way to identify low- and moderate-income people in your community? Does using census tracts or income information work best?
Should "process" be included in the CRA examination? If so, how should process be considered? Can it be considered without being too subjective? For example, should work on a long-term project be counted if there is a clear loan or investment as a goal?
How should the matrix be changed? Should each category be mandatory? Could there be another method, such as meeting four out of six measurements? Best four out of six?
What is the best way to measure community development impact? Should it be limited to projects that affect a high percentage of low-income members of the community? Should it be limited to low- and moderate-income geographies? Give an example of a community development project in your assessment area and describe how it would be rated under the current regulation. Then explain how you think it should be rated.
What work is your bank doing that goes unrecognized? How should the regulation be changed to recognize this work?
How should investments count? Should they be a separate, mandatory category?
What is the best way to evaluate small "big" banks? Should some of the categories, such as investments and community development loans be voluntary for extra points?
Should the regulation recognize any economic development or remain limited to low- and moderate-income projects?