Whether, as Stella Adams suggests in her article, race should be explicitly considered in evaluating a financial institution's CRA performance or, as Lawrence White suggests in his piece, stronger enforcement of the existing fair lending and antitrust laws make CRA unnecessary, these issues deserve serious debate.
These entities would probably be supervised at national level. The market would become more fragmented and all the conditions for a race to the bottom would be present. It might thus be appropriate to have such entities supervised at European level. The current review of the European rulebook offers a chance to adapt the relevant rules.