As the Senator knows, as a practical matter, although CRA is triggered generically in two circumstances--one, part of a periodic review; the other, when applications are made for charter changes or new branches or mergers or acquisitions--as a practical matter, the only opportunity community groups have is in this application process which the Senator has described. That is the only opportunity. So if you foreclose them by a standard that is unreasonable and difficult to meet, you have, for all intents and purposes, foreclosed community groups from registering any effective concerns that they have.
William Bryan: “As the Senator knows, as a practical matter, although CRA is triggered generically in two circumstances--one, part of a…”
Editor's note · Context
Discussing the implications of the Community Reinvestment Act (CRA) on community groups.
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