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fed-occ-fdic_jan2006_craQandA.pdfWoodstock Institute has submitted comment letters to federal banking regulators regarding the Proposed Interagency Questions and Answers regarding Community Reinvestment.  

During the 2002-2005 regulatory review process, and again in this Q & A, Woodstock Institute has sought to clarify that any activity for which a bank receives CRA credit should directly impact low- and moderate-income people.  Under the current regulatory guidance, banks may receive CRA credit for investing in projects that benefit middle- and upper-income individuals if that project is located in a designated distressed or underserved middle-income non-metropolitan geography or disaster areas.  The letter also addresses the key concerns Woodstock Institute has raised during the past year regarding the evaluation of banks under the new intermediate small bank test, how innovative financial services are considered, and how innovative long-term investments should be considered if they extend beyond a single evaluation period.