ots_jan2005_2004-53_cra.pdfComment letter opposing the Office of Thrift Supervision’s proposed changes (No. 2004-53) to their regulation of the Community Reinvestment Act. The proposal would change the way that a “large” institution’s CRA rating is assigned, as well as broaden the definition of “community development” to include activities that do not benefit low- and moderate-income households and communities.