The solution isn't to just avoid that space altogether. It is the exact opposite. It is to provide regulatory certainty and legislative clarity that does not exist currently.

your proposal is so flawed that covered banks are telling us that they see it as a very bad rulemaking.

your proposal decouples CRA from outcomes for intended communities, discounts the value of direct lending and mortgages.

What is the rush, what are you afraid of, or why don't you listen to the people who would be regulated by this and affected by this?

the CRA was a civil rights bill meant to address the legacy of redlining and discrimination in banking.

hatred is a threat to democracy.

we can never sit back and take it easy and take things for granted because if we do, we allow history to repeat itself.

In low- and moderate-income communities, particularly communities of color, the way you build wealth for those communities, the largest investment that they will make is in their mortgage.

congratulations on one thing: you have unified them all.

CRA laws passed to reduce discrimination in the credit and housing markets including what had passed the Fair Housing Act of 1968.

It would become a disincentive for individuals in these communities to lend money in these communities to people of color and of low- and moderate-income, exactly the opposite of why CRA was created.

If CECL causes more small lenders to close their doors, the already growing problem of banking deserts and unbanked individuals will be exacerbated.