---
title: "Former CFPB Acting Director Dave Uejio Discusses the Proposed CRA Rule Change"
url: "https://fairplay.ai/podcast/former-cfpb-acting-director-dave-uejio-discusses-the-proposed-cra-rule-change/"
description: "In episode three of CRA/FYI, hosts Abby Hogan and Donna Murphy welcome Dave Uejio, COO of Prosperity Now and former CFPB Acting Director."
author: "Kevin Allen"
date_published: "2026-09-23"
date_modified: "2026-09-23"
image: "https://fairplay.ai/wp-content/uploads/2026/09/FairPlay-x-Prosperity-Now-1.png"
---

> More FairPlay resources: fetch the curated index at https://fairplay.ai/llms.txt

# Former CFPB Acting Director Dave Uejio Discusses the Proposed CRA Rule Change

In episode three of CRA/FYI, hosts Abby Hogan, FairPlay general counsel, and Donna Murphy, FairPlay advisor and former OCC regulator, welcome Dave Uejio, Chief Operating Officer of Prosperity Now and former Acting Director of the Consumer Financial Protection Bureau.

The group discusses the proposed changes to the Community Reinvestment Act announced by the OCC and FDIC July 31, notably without the Federal Reserve’s involvement. They cover the proposed asset thresholds, which by Uejio’s math would move roughly 391 banks out of the full three-test regime.

Comments on the proposal are due Oct. 13.

# Watch the full episode below:

# Time Stamps:

**[00:00]** Welcome and introductions

**[00:53]** Dave Uejio’s background and connection to CRA

**[02:08]** Background on the proposed CRA rule changes

**[04:33]** A lack of consensus around the need for changes to the CRA

**[05:33]** Exploring the possibility of a rule that can make everyone happy

**[06:49]** Winners, losers, and large bank designations in the new CRA proposal

**[10:26]** Proposed CRA rule changes’ impact on small banks

**[12:49]** Potential changes that could result from the proposed changes to the CRA

**[16:54]** The impact of the proposed changes on rural areas

**[19:00]** What Dave Uejio would change about the CRA proposal

**[22:59]** What Donna Murphy would change about the CRA proposal

**[25:14]** CRA data users, the operational reality of the rule for grantees, state-specific considerations, and the changing lending landscape

**[30:57]** The importance of the comment period

**[32:00]** Next steps for Prosperity Now with the proposed CRA rule changes

**[32:34]** Conclusion

# Transcript:

**Abby Hogan:** [00:00] Hello, and welcome to the FairPlay podcast on the Community Reinvestment Act. We have some incredible guests today. We’re joined by our own FairPlay advisor and former OCC regulator, Donna Murphy. We’re also joined today by former CFPB, former regulator, Dave Uejio, now at Prosperity Now, to talk through the proposed new rule on CRA, kind of what it means for different stakeholders in the CRA ecosystem, and different perspectives on what CRA is doing today, what it could do in the future, and how this new proposed rule could affect all of that. So, let’s start us off with introductions. All of you have gotten to know myself and Donna pretty well over the last few episodes. Maybe, Dave, could you start us off? What have you been doing since you were a regulator, what does Prosperity Now do, and what does that have to do with CRA?

**Dave Uejio:** [00:53] Sure, thanks, Abby. As you mentioned, I’m Dave Uejio, I’m the chief operating officer at Prosperity Now. We are a national nonprofit really working to make sure that everyone, especially families, low- to moderate-income families, have a clear path to financial security and the ability to build wealth in the American economy. As you mentioned, before Prosperity Now, I spent several years, really two decades in federal service, including as acting director of the CFPB, which also put me on the FDIC board, and later at the Federal Housing Finance Agency.

And so when we think about Prosperity Now, we are a national intermediary that works at the nexus of community groups who are providing real transformative services to people in each and every community in America to help them build assets, build wealth, and the banks that are covered by a CRA. Some of our major funders are banks through the CRA obligations that they have, you know, been subject to traditionally so that’s kind of where we sit in that value chain and excited to be here.

**Abby Hogan:** [01:55] Awesome. Thanks so much for joining us. I guess starting off, was the proposed rule, the notice of proposed rulemaking for CRA, was that a surprise to you or was that something you kind of knew was coming down the pipeline?

**Dave Uejio:** [02:08] Yeah, unfortunately it was not a surprise to me. And I imagine it was not a surprise to any of us on the call and maybe some of your viewers. You know, this felt to me like a direction that was signaled as soon as the agencies moved to rescind the 2023 rule. And really, you know, even if you look to the more recent past, you know, the OCC went their own way on CRA once before in 2020, and the the stated goals in the rulemaking proposal, things like statutory alignment, burden reduction, additional regulatory clarity, you know, are legitimate goals that we have heard requests for from various corners of the industry for some time.

And so, I wasn’t surprised to see the proposal come out, and you know I would say with a wider aperture, this is a rule and a legislative framework that has been subject to multiple changes over time.

You know, I’m a bit of a student of history. And so, as I think about the fundamental statutory purpose of CRA, it is not surprising to me to see how the proposal has kind of landed. CRA itself didn’t come out of nowhere way back in 1977. You know, it was really the second half of a two-part strategy.

In 1975, the same coalition that brought about CRA, community organizations out of Chicago, led by Gale Cincotta worked with Senator (William) Proxmire on Senate Banking first to build the Home Mortgage Disclosure Act, which really required banks, as you know, to disclose where they are lending. Within a year of achieving that legislative victory, those groups across the country were then using that data to make the case to Senator Proxmire, who on the Senate floor himself said that HMDA data removed any doubt that redlining and disinvestment were real.

And that coalition then went back to the banking committee and said that that sunshine, that sunlight wasn’t sufficient to rectify the problem. They needed an affirmative obligation from banks to invest in their communities, which is sort of how we got here. And so since that time, there were major overhauls to CRA in 1989. And I think as we’ve gotten closer to the more recent present, you’ve seen clear from 2018 all the way through 2023, the sort of different pendulum swing approaches to revising this regulatory framework. So to me, another swing of that pendulum is not at all surprising.

**Donna Murphy:** [04:33] Yeah, and Abby, I think as we’ve talked about on the past episodes, you know, it is not that there’s a general consensus really that there is a need to modernize and update the current regulations, but there’s a lot of disagreement about how to do that. I think, I don’t know if I would call it a surprise, but one of the things that’s really interesting and is going to be very impactful as we watch it play out, is the fact that the Federal Reserve did not join the the Notice of Proposed Rulemaking (NPR) with the FDIC and the OCC. And that’s one of the things that was a real concern back in twenty twenty when the OCC did its own rulemaking, was the lack of consistency among the agencies.

**Abby Hogan:** That’s a great point. I guess thinking through, Donna, having been in the regulator seat here doing some of these former rulemakings, the prior versions here, do you think we’ll see a world in which we don’t have this kind of hard pendulum swing back and forth? Do you think it’s possible to get to a CRA that makes everyone happy and that could stand the test of time?

**Donna Murphy:** [05:33] So, you’re going to try and get the optimist in me out. Okay, I could hope and I do hope that at some point we can get to a consensus on the things that are consensus-building across the political spectrum, across the spectrum of all the interested parties. Because I think there are some. And, you know, I would love to see a point where we at least get those updated in the rule and then work on the other points to try and build consensus piece by piece because I think that that would be the most lasting and impactful.

This back and forth with rulemaking, and then rescinding, and then rulemaking, and rescinding, is not good for anybody, I don’t think, in the ecosystem. It just disrupts and it directs resources away from the really important work of community investment and lending to those underserved LMI communities.

**Abby Hogan:** [06:25] Certainly, yeah. It’s not good for bankers either. Having been inside a few banks having to deal with the compliance requirements, the back and forth is really challenging. On that note, Dave, thinking about this proposed rule, so looking at our most imminent future for the Community Reinvestment Act, do we think the proposed rule, is it a good rule, is it a bad rule, is it mixed? Who’s winning, who’s losing with the current proposal?

**Dave Uejio:** [06:49] Yeah, I’m going to do that thing that you probably don’t want me to do, which is at least try to resist a pure winners and losers framing, because the honest answer is that the agencies themselves say they don’t have enough information to quantify several of the distributional effects of the rule. If you look at the regulatory analysis that the FDIC put out, that’s something they freely acknowledge and something I take at face value. It really argues for building a stronger record during the comment period. That’s why the comment period is particularly useful for this rule, rather than assuming that this is a rule that is maintaining the status quo, which I don’t think anyone really believes, or that is a rule that’s fundamentally going to compromise the statutory purposes of the rulemaking that preceded it.

I have a couple of examples of that.

When I think about it, and really hewing to the agencies’ own numbers, to me the biggest fundamental shift here is the change to the tiering and the requirements that come with it for institutions of different sizes. Today, small is considered under $412 million, intermediate is around $1.65 billion in cap, and large is everything else. As you know, the proposal moves small to $1 billion and large to $10 billion. By my back-of-the-envelope math on that, of the 3,600 or so banks that are supervised, 477 are examined as large today, and 86 would remain large. So about 391 institutions move from that full three-test regime down a tier, and then, obviously, 814 banks between $412 million and $1 billion aren’t subject to the community development test at all.

For banks moving down, you could argue that the regulatory burden is in some way addressed, although I think it’s important when we talk about community banks to draw lines about who has been exempt from these requirements to begin with. The open question in my mind is then, where does that leave the overall foundational purpose of the law? Where does that leave community development? The agencies argue that this rulemaking restores things to a 1995 distribution by asset share. By their numbers, they had that at 86.2%, and they’ve got it at 85.4% if this rule were to move forward. But that’s just one dimension. When we think about the broader landscape of banking, lending, and community development since 1995, things have changed dramatically, and one of the things that has changed the most is the amount of consolidation and the overall structure of that market. In 1995, about one bank in five was examined under the full large bank regime. This rule would take it to one bank in 40. That’s a pretty pronounced change in coverage.

The other piece that I don’t always hear discussed is the reporting requirements here. We’re really talking about two separate things. One is the test by which you are examined from a compliance perspective, which changes based on your tier. The other is about the availability of the data at all. That’s the thing I am most closely watching when it comes to this new rule. The old adage is that what gets measured gets fixed. If we are closing the aperture of what is being measured and publicly available, it seems less likely that we’re going to be able to fix those things.

**Donna Murphy:** [10:26] You brought up the great contextual point there, Dave, that the foundation of CRA initially was the Home Mortgage Disclosure Act data reporting, and then the small business and small farm reporting was added in CRA, but only for large banks. When that number goes way down, then you have a lot less of that transparency, which is a really important point.

Looking at the other end of the spectrum, the reason that the small banks are only subject to a lending test is based essentially on the banking model that was in place in the 1990s and 2000s. We now have a lot more small banks that don’t do mortgage lending. They may do small business lending, or they may not. We have an increasing number of digital-forward banks that may not do any of those kinds of lending and may only do consumer lending. Taking the community development aspect of CRA away from those banks could be impactful in a negative way for some of those banks in terms of being able to meet the tests. So, I think there are a lot of different nuances here that need to be considered as we look at this rule.

**Abby Hogan:** [11:40] Definitely. And unless you’re a data nerd yourself, a lot of people don’t think about what the availability of the data means. Banks use this data, community groups use this data, lots of people use the data for different purposes. So even if it seems like a good thing for banks or a good thing for industry not to have to report all of these data, the reality at the end of the day is that you’re still going to need the same information available for your exam. You’re still going to have to collect and maintain the data, even if you’re not reporting it. But when the reporting requirements shift, then you have less insight into what other industry players are doing. So it’s not the clear-cut win-win that some folks have said it is.

So Dave, you have a pretty unique insight in your current role into the way some of this investment is making it into communities. Can you talk to us about the impact of CRA more generally on underserved communities, and then the potential changes that could happen as a result of the proposed rule?

**Dave Uejio:** [12:49] Sure. That’s obviously Prosperity Now’s biggest stake in what’s being proposed here, and something we’re uniquely situated to provide perspective on, because we’re able to tell that story at two simultaneous levels.

The first is that Prosperity Now has historically engaged in quite a bit of research and analysis in this space, along with a lot of policy educational work, and the research level is actually quite clean on this question. The reason for that is because metro area boundary redefinitions — basically, when metro areas change over time in a way that has nothing to with regulatory changes — it creates natural experiments for people. Neighborhoods basically gain or lose CRA eligibility for reasons that have nothing to do with the neighborhood geography.

If we look at that research, there are a few insightful points. There was an [article that came out of the Philadelphia Fed by Lei Ding and Leonard Nakamura](https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2635461) showing that after the 2013 split of a Philadelphia metro division, tracts that lost CRA eligibility saw home lending by covered banks fall. Of course they did. In the cycle of that, nonbanks then moved in, which is great, but in the aggregate, what the Fed found is that the replacement lending that flowed from nonbanks only made up about half of what was lost. Similarly, [Ding, Lee, and Bostic](https://www.tandfonline.com/doi/abs/10.1080/07352166.2020.1808005) found that same asymmetry in small business lending nationally, which provides a strong evidentiary base that losing eligibility hurts communities more than gaining eligibility coverage helps. That’s something I think is really important for us to double-click on, because it speaks directly to what happens when coverage is withdrawn. There’s also an article by [Butcher and Muñoz](https://www.huduser.gov/portal/periodicals/cityscpe/vol19num2/ch7.pdf) that found no difference in delinquency rates between eligible and ineligible tracts, which I think is a good evidentiary basis that the idea that CRA somehow pushes banks into risky lending really isn’t the case. The literature is not unanimous, and there are countervailing studies there, but I think these are strong articles that are worth our consideration at an analytical level.

From our work at Prosperity Now, where we are also deeply engaged with over 86,000 members and over 5,000 community organizations providing real asset-building community services at the neighborhood level, the practical implication is very pronounced. When we think about where our network is based, whether that’s folks who are able to originate small dollar mortgages, CDFIs, or other lenders that can make a modestly priced starter home achievable. If you think about those organizations providing rehab loans that can allow homeowners to replace their roof without having to get a payday loan. If you think about a small business origination that lets an operator cover payroll through a cash flow gap, or add additional inventory to make their community-based small business more prosperous. And if you think about grants that keep free income tax prep sites operating, or housing counseling agencies able to operate and steer people away from more predatory, more dangerous financial products to become more responsible homeowners through financial coaching. Those are exactly the kinds of services that might be implicated by the changes to who is able to offer those services and at what cost parameter. Those are kinds of things that are lending adjacent, but they’re really fundamental to communities all across the country, particularly in rural and tribal areas. So the stakes are high, and they’re very real for communities all across the country.

**Abby Hogan:** [16:40] Those are really important points. Donna, as a regulator, did you see similar trends in terms of community investment and the impact that CRA had on communities, or did you observe anything different?

**Donna Murphy:** [16:54] Generally, I would definitely agree with Dave’s points that he raised. The impact of CRA is tremendous across the country. But we do see differences. I’ll just double-click on one of his points. We do see differences between areas where there are concentrations of bank offices or branches and areas where there aren’t, which are sometimes called CRA deserts.

One of the things that I think is particularly important, and that Dave just raised, is that some of the analysis that’s been done of the proposed rule is that it could have the greatest impact in terms of a decrease in community development lending, investment, and services in rural areas. While it would add tribal areas for the first time specifically to the rule, which is a great thing, there is a concern that the change particularly in the asset thresholds for banks could lead to significantly less community development investment, lending, and services by banks in those rural areas, which would be a real loss. There are lots of other communities that would be impacted as well, but I think the rural areas may not have been mentioned as frequently during these discussions.

**Dave Uejio:** [18:15] If you think about the counties of persistent poverty, I think 75% of them are rural. That’s not anyone’s subjective opinion. That’s just what the data shows. So, those are things that I’m particularly keeping an eye on.

**Abby Hogan:** [18:31] Those are all great points. Thinking through some of those nuances and subtleties in the proposed rule, and what that means for communities, are there things you would change if you had the pen on this rule? We’ll start with Dave. Are there things you would change in the proposal to walk that line, helping communities continue to receive the investments they so deeply need while reducing some of the burden on the industry?

**Dave Uejio:** [19:00] Sure. Obviously, this is maybe not the rule that I would write, but if I were writing this rule, there are a handful of things that I think are worth considering changing.

One is to keep community development on the report card. If a bank is falling short on community development, it shouldn’t be able to earn a passing grade. You can simplify how you measure that without making it entirely optional.

The second thing I’d consider is that we ought to grade banks on what they actually do where they actually do it. The proposal offers two ways to pick which lending gets evaluated. One is across the whole institution, and one is assessment area by assessment area. To the point we were just making about the way that this is playing out and operationalized in neighborhoods and communities, they really ought to take the second. Their own example in the proposal makes that case. A bank whose farm lending is small nationally, but who is a significant farm lender in a particular rural assessment area, under the institutional-level that’s proposed, that lending just disappears from the evaluation, in a way that would seem to cut against the implicit objective in the rulemaking.

The third thing they ought to do is keep an eye on whether ordinary people can get access to a basic, affordable bank account. From our perspective at Prosperity Now, that’s a key component of financial security, is your ability to have access to the banking system. It is an objective that has enjoyed broad bipartisan support over administrations. Buried in the proposal is the position the agencies are taking about what constitutes credit, and that’s a whole separate call with a lot of lawyers on it. But from our perspective, I think we can all agree that access to a bank account is an imperative for financial security. Even under the narrowest reading, nothing’s really stopping the agencies from publishing enough data that we could tell. And if you believe that the statutory purpose of the rule is to provide sunshine, transparency, and the ability to assess these things, that seems fairly fundamental to me.

Fourth, and maybe it should have been first, but from my perspective, I don’t think you should make it harder for banks to fund community organizations. The proposal caps how much overhead a bank can count toward a grant at 15%. My understanding is that number is derived from a federal grant-making rule where, in that context, it’s actually an option for groups that don’t have some other negotiated rate. It is not necessarily a threshold above which something is defined as waste, fraud, and abuse. I think organizations should be able to use the rates that they’ve already negotiated with the federal government, and let banks rely on financial statements that already exist, rather than creating a new bureaucratic regime that is shifted onto community organizations who are ill-suited to meet those.

And then five, I think we ought to keep collecting data, even if you’re simplifying the forms, even if you’re simplifying the examination requirements. It’s the thing that I’m most passionate about. Reducing the exam burden and going dark or limiting visibility into the numbers are two separate decisions, even though at points the proposal seems to consider bundling them. I don’t think they need to be bundled. In any instance, I think a plan for ongoing monitoring once the rule takes effect would also be valuable, mostly because I don’t imagine this is the last word on what we’re going to see with this law.

**Abby Hogan:** [22:23] I couldn’t agree more on the data piece, keeping those two as separate decisions. I think we’ve extolled the virtues of continuing to collect and report data, even if you don’t have the regulatory burden of the exam that goes alongside it.

**Donna Murphy:** Because we are all data nerds here, let’s be honest.

**Abby Hogan:** Three-for-three. Guilty as charged.

[22:44] Donna, same question. If you had the pen right now, and you were handed this rule and told to help get it across the finish line in the best way possible, what are some of the tweaks you would consider making, or ideas you would recommend digging deeper into?

**Donna Murphy:** [22:59] I don’t want to repeat any of the ones that Dave made, but a lot of those would definitely be high on my list, including the issue of data reporting and ensuring transparency.

Following up on the point I raised earlier is hoping agencies would dig in and look at what the impacts would be on particular LMI and underserved communities from some of these changes, and whether there are ways of mitigating those within the framework of what’s being proposed.

The third one I would add, which I don’t think Dave touched on in his list, is looking at ways that technology-forward banks, banks that have just a main office, how they’re evaluated. What the proposal does, which is great, is continue the strategic plan option, which many of those banks do go to. But it seems like we’re getting to a point where there are enough of those banks that maybe there should be an evaluation of how those banks are evaluated, and whether there’s a different category or a different approach, to make sure that those banks are evaluated fairly and appropriately under the CRA when they operate in a way that just wasn’t imagined when the last major rule writing was redone in 1995.

**Abby Hogan:** [24:24] Those are great points about the strategic plan banks. That has become an even more frequently used tool of some of the larger and savvier banks more recently, basically working with the regulator to say, “Hey, these are what we think our targets should be,” and allowing banks to self-measure with a regulator-approved plan. It’s no question why those have become more popular among the more sophisticated banks that have the data capabilities in-house or unique business models.

Starting to wrap up here, are there any perspectives on this discussion of CRA more generally, or the proposed rule specifically, that you haven’t heard vocalized just yet, or other discussions that you think we should be having that you haven’t been hearing in the CRA ecosystem?

We’ll start with you, Dave.

**Dave Uejio:** [25:14] I think there are three to lift up, and we’ve touched on each of them.

The first is your point, Abby, that there is this vast array of stakeholders who use CRA data rather than produce it. Researchers, fair lending experts, local governments, and this sort of audience, the people who are checking on whether models and underwriting are actually reaching low- and moderate-income neighborhoods. This really exists in equilibrium with the Home Mortgage Disclosure Act data. The statutes were built as a pair. Disclose, then obligate, and use that disclosure to then check. If you’re thinning out disclosures, that’s a compliance decision in the first instance that’s going to have downstream consequences that we sometimes don’t always appreciate. Weakening that feedback loop runs a risk that hasn’t necessarily been elevated to the degree at which it ought to be.

The second is the one that I think is one of the reasons you invited me here: What is the operational reality of this rule for grantees? A lot of the debate around things like the indirect cost provision has been about, should banks should get credit for making grants to nonprofits? If you move down that analysis, though, very little of the discussion I’ve heard has been about what exactly we think a 15% cap and a new documentation regime are going to mean for the small, rural, or tribal nonprofits that need to produce them. There’s a bit of an irony, I think, in framing an overall proposal as being about the reduction of burden, rather than as a simultaneous burden shift to nonprofits who have the least resources to absorb that kind of implementation of a new regime.

And then the last, and this is my view, not Prosperity Now’s view, I’m going to be very clear about that, is something that Donna said: all of this is happening against a backdrop of a lending landscape that has changed dramatically, and it continues to change. I think a lot about the old Wayne Gretzky adage, that the right way to approach things is to skate where the puck is going to be. What’s very difficult as a regulator is that frequently we are writing rules to where the puck once was, and that’s tough. This lending landscape continues to accelerate. You see the points that Donna made about nonbank lenders in the mortgage space. There’s also this cyclical move from financial companies trying to become banks at this time. As a regulator, it’s very difficult to try and get ahead of all that. You can’t see the future with perfect clarity here.

There is this open question, to go with Donna’s mortgage example, you have mortgage lending that is now principally originated by nonbank lenders, and they reach LMI communities. I don’t necessarily have an issue with that, but it is creating greater and greater diffusion. And the fact that the Fed didn’t come along with this rulemaking, to Donna’s point, creates the potential for a fairly arbitrary distinction based on where one is chartered, not one’s asset size, about what regulatory regime you’re subject to. That must make it very difficult. I’ve never been a compliance officer at a bank, but I can empathize with how much complexity that inserts into the system.

The last point is that you’re seeing an increasing uptick in state level CRAs. That is in some ways a reaction to this particular swing of the pendulum. For example, New York’s nonbank statute just went into effect recently and covers nonbank mortgage lenders. Until we can get our arms around a unitary model, you’re going to continue to see things that give compliance officers migraines. What I always heard as a regulator from banks is that they want clear rules of the road, with a level playing field and a single unitary regulatory regime. Well, this is kind of far from that, and I worry that if it’s not done with a considerate and deliberate approach, it risks further fragmenting the response.

**Abby Hogan:** [29:43] I couldn’t agree more. My first job outside of the bureau when I left was at this fintech, and we had to maintain 50 individual state licenses, and then manage all the 50 plus state and locality regulations. So, as soon as the discussion with the administration changed to, okay, we’re going to eliminate regulatory burden by changing the federal posture, and then all these states come in, I think those of us who’ve worked at any of these institutions that have had to comply with all 50 state rules individually, rather than just the nice, with one federal regulator, we all knew what was coming. Whether you like the federal regulatory posture or not, having one regulator you can look to for everything … it’s nice to have one set of guidelines rather than 50 sets of guidelines, even if you like them better. The complexity, expense, and time of keeping up with all of those is immense. So, I could not agree with you more on the fragmented regulatory landscape.

Donna, same question to you. What other discussions do you think have been missing? Do you agree with the list that Dave provided, or do you have others that you would recommend?

**Donna Murphy:** [30:57] Dave brought up the points that I was going to raise on that, which I haven’t heard. I think it’s really great that there is an active discussion and debate going on about the various points that we’ve been talking about, for the most part. I haven’t heard the state CRA considerations as much, so I was definitely going to raise that one.

What’s important is that all of the interested parties know that the comment deadline for this rulemaking is October 13. So it’s coming up on us quickly, in less than a month. It’s really important that the federal agencies at the FDIC and the OCC hear from all the interested stakeholders, and I do mean all the interested stakeholders, about how this would impact and how the proposed rule can be improved before it is finalized. That’s really critical. It’s a great aspect of our federal rulemaking process, and I strongly encourage all the interested parties to comment on it.

**Dave Uejio:** [32:00] To that end, Donna, we’re going to be going to our 86,000 person network with a pulse survey, and asking some questions to really understand and granularly distill, community by community, district by district, who are these nonprofits, and what they are doing directly to support the community, and what would be the effect of the rule on them if the 15% cap in particular is enacted (as well as other thoughts)? Many of them also originate loans and provide a variety of services to LMI communities all across the country. So it’s really a great point.

**Abby Hogan:** [32:34] That’s a great reminder, so don’t forget to get your comment letters in before the deadline. That will creep right up on us. In terms of next steps in this rulemaking, we’ll see how quickly it moves along. As we’ve discussed before on this podcast, we’re expecting a fair amount of legal challenges to this one, given the number of impacted stakeholders. So the likelihood that the rule would be finalized on a standard rule timeline are slimmer on this one, but we’ll have to wait and see what happens.

Thanks so much for joining us, Dave and Donna, discussing all of the proposed changes, how they impact different stakeholders in the ecosystem, ways to think about this new proposal, and all of the ways that we could recraft this rule to think about all the different stakeholders involved.

**Dave Uejio:** Thanks so much. Really appreciate it.

**Donna Murphy:** Thanks, Abby. Thanks, Dave.