From the full comment letter:
The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) strongly oppose the OCC and FDIC’s proposed Community Reinvestment Act (CRA) regulations. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive financial practices. CRL is an affiliate of Self-Help, one of the nation’s largest nonprofit community development financial institutions. Over 40 years, Self-Help and its affiliates have provided over $8.5 billion in financing through 159,000 loans to homebuyers, small businesses, and nonprofits. It serves more than 150,000 mostly low-income members through 60 retail credit union locations in California, Florida, Illinois, North Carolina, South Carolina, Virginia, and Wisconsin.