Amid the large volume of comments on the proposed revision of the Community Reinvestment Act regulations, we may be losing sight of the fact that CRA is serving its original purpose less and less effectively as time goes on. Nothing in the proposed regulations will reverse that trend.

This is not to deny that the proposed changes are important and will affect the way banks and thrifts do business, or that bankers have expressed very legitimate concerns with the regulations. The fact is simply that a steadily larger share of home mortgages is completely outside the boundaries of CRA.

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