The agenda has been posted for the FRB and Reg. B is item no. 2. 23A and B are also accounted for.

"Final amendments to Regulation B (Equal Credit Opportunity) that would conclude the Board's review of the regulation. (Proposed earlier for public comment; Docket No. 1008)"

Will it be a trick, or a treat? Voluntary GMI gathering?

When was the last time you got a "treat" from Washington?

Hey, sometimes you read a new reg and you just want a cigarette when you're done.

I'm saving that reaction for the repeal of CRA.

What about the repeal of TIS? They've been promising that one for years. I'm still waiting.

When I'm dreaming, I always travel first class! TIS is a coach-class expense compared with CRA.

Editorial Comment by a Vendor

Richard

CRA going away? I don't think it will be in my lifetime. Until it is fully embraced by all institutions so that information generated will statistically prove its not needed, it will continue to impose a hugh expense on the industry.

Unfortunately, some still don't get it and 90% of the industry pays for their lack of insight. Has it helped? There are studies that say it has generated funds that have erased blighted areas and created economic successes all over the US.

A Treasury study indicated institution that participate actively increase their market share and those that don't have a decreased market share. Another Treasury study says loans losses do not increase as a result of CRA participation. Contrary to what Phil Graham was expousing a couple of years ago.

There are many problems with CRA, and the biggest is the lack of a standard and simple methodology to collect and analyze the data. There is a heavy burden placed on individual compliance officers to create their own system. So the industry has a hodge podge of programs created by individuals who are doing the best thay can without the training, resources or management support, needed to develop systems that provide a real solution.

I believe if that were resolvd, CRA and compliance in general would not be the mental and physically draining process it has become. Instead, realiation that it is the best marketing tool an institution ever had will become evident.