WASHINGTON-CUNA submitted an official comment letter with the Federal Reserve recently commenting on possible amendments to Community Reinvestment Act regulations. In the Feb. 6 Federal Register, the Federal Reserve published a joint Notice of Proposed Rulemaking which would ease reporting requirements for "small institutions" by changing their definition under CRA. In CUNA's letter, Associate General Counsel Mary Dunn wrote that the banking regulators are best suited to revamp the regs, just as credit union regulators are best to determine credit union regulatory changes. Dunn also pointed out that the amendment to the definition of a "small institution" would "substantially lessen the CRA performance standards for 1,100 institutions." "The Community Reinvestment Act was enacted in 1977 to encourage banks and thrifts to meet the credit and deposit needs of their communities, including low-and-moderate-income areas, consistent with safe and sound banking practices," Dunn wrote. "It is well documented that Congress recognized that overall, banks and thrifts had a poor record of serving their communities and they often focused instead on opportunities outside of the market areas from which they received their deposits. "CRA has been a federal law for twenty-seven years, and we believe there is evidence that the Act and implementing regulations have had a positive effect in seeking to ensure that those institutions with a record of failing to serve their communities make measurable efforts to do so."