One possible reason for the lack of comments is that many bankers regard the revocation as a good thing - and it is in that the 2020 Rule was beyond complicated - it was convoluted.
However, in the NPR the Agency posed some questions about possibly retaining some elements of the 2020 Rule, notably the process to get clarification on potential CD activity. That was one of the good things in the 2020 Rule. So some BOL readers may want to express support for that idea.
The 2020 Rule also expanded the definition of a renewal to include lines of credit evidenced by demand notes. Banks that extend lines of credit secured by the personal assets (AR and Inventory and equipment) typically use demand notes for the full amount of the line (to protect the seniority of the UCC filing). When those lines of credit are "renewed" (the conventional meaning of the word) by commercial lenders they are mot qualified as "renewals" under the 1995 Rule because the maturity of the note is not extended. This results in, what I suspect, underreporting of a large number of small business loans. I had written the OCC about this and they did reflect my concerns by expanding the definition of renewed loans. So that is another area that bankers may want to comment about (the Agency won't keep that if it reverts to the 1995 Rule but it will be an indicator to them that they should include that provision the next time they amend the CRA)..
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps