From the full comment letter:
The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) strongly oppose the OCC and FDIC’s proposed Community Reinvestment Act (CRA) regulations....
The most troubling outcome of theproposed rule is that it would unwittingly sanction redlining. The proposal relies on an overly simplistic evaluation measurethat focuses on the total dollar value of CRA qualifying activity.We strongly oppose this approach, which we believe would fail to hold banks accountable for meeting the convenience and needs of all of their communities, as required by statute.