of 2022. Community groups submitted a position paper on March 1, 2022, to the OCC, FDIC and Federal Reserve about the key reforms they wanted to see. These included a consideration of race on CRA exams, more objective measures of performance that reduce ratings inflation, and expanded CRA assessment areas that include not only where banks have branches but also areas with significant amounts of bank lending and/or deposit activity. The groups also recommended that CRA be expanded to apply throughout the financial sector, beyond banks. This would require Congressional legislation, but there were precedents in state CRA laws that apply to mortgage companies and credit unions, not just banks. Criticisms Effectiveness The first major research study of CRA was the 1993 book Community Reinvestment Performance (1993, Probus Publishing) by Kenneth H. Thomas, Ph.D., a Finance Lecturer at The Wharton School of the University of Pennsylvania. The main conclusion of the book, which was based on an analysis of the results of 6,706 CRA exams, was that the law was needed and it works but it must be improved, mainly through better and more objective enforcement to avoid "CRA Grade Inflation". Many of the recommendations in that book were included in the 1995 CRA reform. The CRA Handbook (1998, McGraw Hill) carefully examined over 1,500 CRA exams under the 1995 reforms and identified further CRA Grade Inflation and made specific recommendations to improve the law's effectiveness, primarily through more objective and quantifiable standards. Some economists have questioned if the CRA was – or at least had become – irrelevant, because it was not needed to encourage banks to make profitable loans to a variety of borrowers. In a 2003 research paper, economists at the Federal Reserve could not find clear evidence that the CRA increased lending and home ownership more in low income neighborhoods than in higher income ones. A 2008 Competitive Enterprise Institute study resulted in a similar finding. Former Federal Reserve chair Ben Bernanke has stated that an underlying assumption of the CRA – that more lending equals better outcomes for local communities – may not always be true, pointing to "recent problems in mortgage markets". However, he notes that at least in some instances, "the CRA has served as a catalyst, inducing banks to enter under-served markets that they might otherwise have ignored". The Woodstock Institute, a Chicago-based policy and advocacy nonprofit, found in an analysis of