More than 35 community, nonprofit small business and minority advocacy groups raised concerns with the company’s underwriting practices, disclosures and CRA plans in a joint Feb. 19 comment letter to the FDIC.

The groups, spearheaded by the California Reinvestment Coalition, said Square should be required to choose 10 to 20 metro areas where it does business and designate those as CRA assessment areas. The groups pointed to additional community investment requirements the Office of the Comptroller of the Currency placed on Charles Schwab in 1999 when it created a branch-less bank as precedent.

“It’s not impossible to find solutions to these types of dilemmas,” CRC Executive Director Paulina Gonzalez-Brito told Bloomberg Law.