In anticipation of the reform proposals to the Community Reinvestment Act (CRA) expected this week, I am continuing the review of performance measures on CRA exams. The most recent blog looked at performance measures on the lending test. This one will scrutinize performance measures on the investment and service test.
“We are already seeing an unusual level of discord among the regulators,” said Jesse Van Tol, chief executive of the National Community Reinvestment Coalition, a fair-lending advocacy group. “I think there is a significant risk that the whole effort will backfire, unless a more careful and consensus-driven approach is taken.”