Comment on the Comptroller of the Currency (OCC) Proposed Rule: Reforming Community Reinvestment Act (CRA) Regulatory Framework by Christopher Grant

1. November 17, 2018
Joseph M. Otting
Comptroller of the Currency
Office of the Comptroller of the Currency
400 7th Street, SW
Washington, D.C. 20219
Comment on the Comptroller of the Currency (OCC) Proposed Rule: Reforming Community
Reinvestment Act Regulatory Framework
Docket ID OCC-2018-0008
Dear Comptroller Otting,
My name is Christopher Grant and I am a second year MBA student at the Stanford Graduate
School of Business. I was born and raised in Baltimore, Maryland and prior to business school, I
advised financial institutions on a wide range of strategic, risk management, and supervisory
matters as an associate at a global consulting firm. In my spare time, I worked closely with
entrepreneurs in low- and moderate-income communities. Their experiences inspired a passion in
me for increasing access to capital in low-income communities.
I learned about the Community Reinvestment Act (CRA) through my engagements with
financial institutions as well as my interactions with minority entrepreneurs. I came to believe
that the CRA is ineffective in its current form and requires a mix of social, political, and
regulatory solutions to change lives, drive economic mobility, and create meaningful change in
marginalized communities. Your effort to reform and modernize the current CRA regulatory
framework is both timely and necessary.
The following recommendations are borne from my personal experience in some of the
communities the CRA seeks to benefit as well as my broader professional experience. The CRA
should:
● Ensure that CRA regulations are more clearly defined, transparent, and consistently
applied to all depository institutions, including bank affiliates, credit unions, and
fintech/internet banks;
● Refrain from adopting a metric-based performance system that’s solely based on “one
ratio” and instead, adopt a community impact-focused CRA performance system based
on a new framework of quantitative and qualitative measures;

2. ● Preserve assessment areas while expanding the definition of “community” to ensure that
CRA appropriately addresses the local needs of underserved communities through
physical branch locations and the broader needs of low- and moderate-income people
outside of the bank or fintech’s branch network;
● Include race and ethnic characteristics explicitly within a modernized CRA regulatory
framework to ensure that people and communities of color are appropriate considered
during CRA examinations;
● Refine CRA ratings to address potential grade inflation issues and provide more clarity
on performance across banks;
● Enhance incentives for ‘Outstanding’ CRA rating performance and consequences for
‘Needs Improvement’ and ‘Substantially Noncompliant’ CRA ratings;
● Safeguard public comments and participation by recognizing Community Benefit
Agreements (CBAs), establishing metrics to evaluate community input as well as
community health, and requiring CRA-focused marketing activities in low- and
moderate-income communities; and
● Examine banks more frequently through the establishment of annual CRA reporting
requirements.
A modernized CRA must keep the credit needs of local communities central to its mission. The
OCC and other regulators should not rush to propose or implement changes without a clear
rationale for why they advance the original purpose and objective of the CRA. Any changes to
the CRA should boost lending, investment, and access to banking services for underserved
communities. Changes should increase transparency, preserve the CRA’s local focus, clarify the
definition of community to include people and communities of color, refine the CRA rating
process, and solicit community input. Please feel free to contact me at ​cgranted@stanford.edu​ if
you should have any questions. Thank you so much for your consideration.
Sincerely,
Christopher Grant