Comment letter on the revised Federal Reserve Board CRA proposal affecting intermediate small banks

fed_may2005_r1225_cra.pdfComments on the revised CRA proposal offered by the Federal Reserve Board for the regulation of intermediate small banks.  Woodstock Institute finds that the proposal is an improvement over the one previously issued by the FDIC and a vast improvement over recent changes the OTS has made to its CRA regulation which eliminated several key provisions.  The letter primarily addresses the elimination of the requirement to disclose small business data, regulation of bank branching, and the implementation of a community development test.