Public Comment, CRA Q&A, Community Capital Management

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COMMUNITY CAPITAL MANAGEMENT Revitalizing America August 3 1,2007 Re: Notice and Request for Comment Community Reinvestment Act; Interagency Questions and Answers OCC: Docket ID OCC-2007-00 12 Board: No. OP- 1290 FDIC: RIN number 3064-AC97 OTS: ID OTS-2007-0030 1. Introduction Community Capital Management ("CCM"), the registered investment advisor to The CRA Qualified Investment Fund (the "CRA Fund"), welcomes this opportunity to comment upon the proposed additions and revisions to the Interagency Questions and Answers Regarding Community Reinvestment published in the Federal Register on July 11, 2007 by the Oflice of the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision (.,cllective!y the "Agencies"). This comment focuses upon two newly proposed questions and answers ("Qs&As"): 5-.12(g)-4, which states unequivocally that a majority-owned financial institution may receive CRA consideration for activities it undertakes with a minority- or women- owned financial institution or a low-income credit union even if the latter institutions are not located in, and their activities do not benefit, the majority-owned institution's assessment area or a broader statewide or regional area that includes its assessment area; and 5-.23(a)-2, which is intended "to clarify that an institution that makes a loan or investment in a national or regional community development fund ...

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