While concern about credit access has begun to resurface in a tightening credit environment, I would hesitate to limit the focus of a new CRA in this way. Access to credit in lower-income areas has been less of a problem in recent years than has been access to loan products that were fairly priced, well-underwritten by lenders, and wellunderstood by consumers.
The analysis that I cited earlier regarding the targeting of lowerincome and minority communities indicates that we continue to have a problem that warrants regulation.