An excerpt
The OCC’s leadership on the need to update and modernize the CRA regulations is laudable, as is OCC’s extensive outreach to CRA stakeholders. As the banking industry and community development industry change, however, CRA regulatory policy has not kept pace and CRA needs to be updated to reflect technological change and interstate deposit taking. CRA administration can be greatly improved with the adoption of the regulatory changes suggested in this letter, without resorting to the risky and simplistic mechanism of a single metric.
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