On the recordMay 5, 1999
I think any fair reading, in terms of the standards of proof, is that a ``substantial'' standard is much higher than a scintilla. In effect, what this provision would do is raise the bar substantially... for community investment groups being able to, in effect, make their case for the consideration--the consideration of the regulator. Even if they make their case that, indeed, the bank has not been responsible, has not done what it ought to do under CRA, the regulator may disregard that and still grant that approval. So it strikes me that by posing a standard before they even get into the ball game of ``substantial,'' you indeed cut off access to much of the input the community groups ought to have before a regulator makes a decision.
Source
govinfo.gov
