151015 EGRPRA Comment Final with Orgs.pdf

This letter submits comments on the Community Reinvestment Act (CRA), bank mergers and acquisitions, and the Consumer Financial Protection Bureau (CFPB) as part of the prudential regulators EGRPRA process. Woodstock strongly encourages the regulators to use this opportunity to acknowledge the importance of CRA and its benefits to communities across the country, as well as identify provisions that no longer serve their original intent because of changes in the financial marketplace. Particular aspects of CRA are outdated and must be modernized to ensure that the Act is working as intended. For example, assessment areas should accurately reflect a bank’s footprint and include all geographies where a bank does substantial business. CRA exams should accurately address whether bank products, services, and practices are adequately meeting the needs of the community and include quantifiable benchmarks for banks to meet. We also support clarifications related to bank mergers and bank acquisitions, including longer comment periods, a more public process, and a true consideration of the bank’s CRA commitments and how the merger/acquisition will provide a public benefit.