Reinforcing its commitment to the controversial proposal to rewrite the Community Reinvestment Act (CRA) rules it issued with the FDIC, the OCC seeks bank-specific data over the past three years on several questions fundamental to understanding the implications of the proposed approach on both banks and low-and-moderate income (LMI) communities.  Data categories in this request track definitions in the NPR and are thus generally not readily available at most banking organizations, complicating submissions despite the light data would surely shine on how the NPR would work in practice.

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