Under the current CRA rules, around 90% of banks receive a “satisfactory” grade and 10% receive “outstanding” marks, the National Community Reinvestment Coalition estimated in a comment letter to the agencies. A “needs to improve” or “substantial noncompliance” score is exceedingly rare. “It was pretty easy to get a pass on CRA exams,” said Mitria Spotser, federal policy director at the Center for Responsible Lending.