In its set of recommendations, the Treasury Department warned that the growth of non-bank lenders competing for loans that would be eligible for the CRA could have future implications for the program.

Congress passed the CRA in 1977, as part of an effort to encourage banks to meet the credit needs of their communities, including low- and moderate-income communities. Federal banking regulators enforce the law by conducting examinations. In 1995, the law was tailored in an effort to account for the different sizes and business models.

In its report, the Treasury Department said that the CRA has not kept pace with the banking industry's "substantial organizational and technological changes."

The recommendations include changes to the program's administrative framework, expansion of the types of activities eligible and more specific criteria for eligibility and ratings.

And the department warns that non-banks could have a profound impact on the CRA.

"This increasing market share by nonbanks places more pressure on CRA-regulated banks, whose Lending Test evaluations are largely based on mortgages and small business loans," the Treasury Department said.

The department recommended in its report that more research is needed on the extent to which non-banks are meeting the needs of low-and-moderate income communities, with a focus on loans guaranteed by the Small Business Administration and Federal Housing Administration.