Anyone familiar with CRA knows how difficult community development lending and investing are. The latest (2003) available market data show that more than one-third of the reporting CRA lenders (2,100) did not originate even one community development loan that year. Moreover, more than half the reporting lenders originated only 2 or fewer community development loans for the period. Community development investment activity is even more difficult. So now the regulators are offering to exchange a "no reporting" provision in exchange for an emphasis on community development activities that makes "satisfactory" in this difficult performance area absolutely mandatory. The proposal states, "It is not the intention of the agencies to permit a bank to ignore one or more categories of community development". Do you want to hinge your bank's entire CRA rating on your community development activities? True, there is an expanded definition of community development (although it remains too restrictive), but many community bankers will have to show an examiner evidence that their bank's performance of only 1 or 2 community development loans or investments was consistent with market opportunities. If that sounds like a risky proposition, maybe you should express your opinion to your regulator. The deadline for public comments is May 10, 2005.