Comment letter submitted in support of the proposed changes
to the rules implementing the Community Reinvestment Act (CRA) as they apply to
assessing an institution’s record of providing low-cost education loans. 
The comment letter also opposes a proposed rule change that would allow
financial institutions to receive favorable consideration under the Community
Reinvestment Act for investments in women- and minority-owned financial
institutions or low-income credit unions outside of the communities in which
the financial institutions does business.