We are writing to encourage you to use your existing authority to improve and update the
administration of the Community Reinvestment Act (CRA). We applaud you for moving
forward with updates to the CRA Questions and Answers (Qs and As) in recent years and hope
that you will continue this process of modernizing CRA administration. As your 2013 proposed
revisions to the CRA Qs and As noted, “This notice addressing several community development
issues is intended to be the Agencies’ first step to addressing substantive and significant issues
raised by commenters.” We propose changes to align CRA better with changes in the economy
and the banking system that do not require you to reopen the regulations or the statute.