NALCAB, the National Association for Latino Community Asset Builders, The National Coalition for Asian Pacific American Community Development (CAPACD), and the Center for Responsible Lending (CRL) write in response to the invitation for public comments regarding changes made to the Community Advantage Pilot Program (CA) noticed in the Federal Register on April 29th, 2022. Access to capital is one of the greatest barriers to success for minority entrepreneurs. Since its inception in 2011 CA has successfully expanded access to capital for small businesses located in underserved communities through Community Development Financial Institutions (CDFIs) and other mission-driven lenders. We appreciate the opportunity to share our perspective on recent efforts to strengthen this program.