On May 20, 2020, the Office of the Comptroller of the Currency issued a final set of regulations intended to modernize the Community Reinvestment Act. While some improvements were made from the proposed regulations, the new regulations suffer from four big problems: There is no evidence of the impact of the new regulations; The primary metric used for assessing CRA compliance neglects community needs; The regulations create a limited and unforgiving test on retail and community development lending, with limited community coverage; and public data will be lost while bank reporting burdens will increase. In addition, the refusal of the other two bank regulators – the Federal Deposit Insurance Corporation and the Federal reserve – to sign-on to these final regulations will create confusion among banks and their community partners as well as opportunities for regulatory arbitrage.