Key Points on CRA Modernization


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With less than a week before comments are due on the OCC’s August advance notice of proposed rulemaking on the Community Reinvestment Act, ABA VP Krista Shonk follows up an earlier podcast interview with tips on how to complete a comment letter and key points ABA will be making in its own letter. In the interview, she discusses

  • Meaningful stories about how CRA strictures have affected banks' business strategies.
  • The importance of banker stories in comments.
  • Views drawn from ABA's CRA modernization working group on key issues like a CRA metric and assessment areas.

For bankers putting the finishing touches on their comments -- due Nov. 19 -- ABA offers a members-only guide to writing a comment letter. Learn more at

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