The central thrust of the CRA is to encourage banks to ensure that all creditworthy borrowers have fair access to credit. For banks to be successful in meeting the credit needs of their entire community, it follows that they must guard against discriminatory or unfair and deceptive lending practices. Ensuring fair access to credit is difficult and requires ongoing vigilance.
15 For this reason, taking a holistic view of closely related issues is likely to be the best way to fulfill the purpose of the CRA, as one of several important laws intended to promote fair financial access.