Testimony of Dory Rand before the Federal Reserve Board, the OCC, the OTS, and the FDIC on the need to modernize the Community Reinvestment Act

fed_cramodcomments_august2010_doryrand_0.pdf

Discusses the types of financial institutions that should have reinvestment responsibilities and the geographies where those responsibilities are assessed. Also includes recommendations to improve the services test portion of the CRA and improve the ratings and incentive structure of the CRA.