Public Comment CRA Q&A AC97, Consumer Bankers Association

September 10, 2007 Office of the Comptroller of the Currency 250 E Street, SW Mail Stop 1-5 Washington, DC 20219 Docket ID OCC-2007-0012 Jennifer J. Johnson Secretary Board of Governors of the Federal Reserve System th20 and Constitution Ave., NW Washington, DC 20551 Docket No. OP-1290 Robert E. Feldman Executive Secretary Attention: Comments Federal Deposit Insurance Corporation th550 17 Street, NW Washington, DC 20429 RIN Number 3064-AC97 Regulation Comments Chief Counsel’s Office Office of Thrift Supervision 1700 G Street, NW Washington, DC 20552 Attention: ID OTS-2007-0030 Dear sir or madam: The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the interagency proposal to revise the CRA Q&A (the “Proposal”), as issued by the federal bank and thrift regulatory agencies (the “Agencies”). CBA is the recognized voice on retail banking issues in the nation’s capital. Member institutions are the leaders in consumer, auto, home equity and education finance, ƒƒƒƒƒelectronic retail delivery systems, privacy, fair lending, bank sales of investment products, small business services and community development. The CBA was founded in 1919 to provide a progressive voice in the retail banking industry. The CBA represents over 750 federally insured financial institutions that collectively hold more than 70% of all consumer credit held by federally-insured depository institutions in the United ...