This comment letter responds to the December 12, 2019, Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation jointly issued notice of proposed rulemaking proposing to significantly change regulations under the Community Reinvestment Act (CRA). The researchers note that while the proposal is a useful starting point for discussion, it needs substantial revision, warranting a new proposal. They applaud the agencies for recognizing the need for CRA modernization and more objective ways to measure how much banks are doing for their communities, and agree that a bank’s ability to confirm whether an activity will count before committing to an investment is a welcome improvement. But the proposal has significant weaknesses and many unknowns, which must be addressed.