community reinvestment

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Mr. Thomas is widely-viewed as the nation’s leading CRA expert and has advised federal regulators on CRA reform.  After reviewing CRA’s origins and purpose, we discuss how the new proposal differs from the OCC’s rescinded 2020 final CRA rule and the current CRA rules, including the proposal’s higher asset threshold for small banks and approach to assessment areas, how industry and consumer groups have reacted to the proposal, and next steps and possible timetable for issuance of final rules. … Continue Reading

As we previously reported, the Office of the Comptroller of the Currency (“OCC”) rescinded its 2020 Community Reinvestment Act (“CRA”) final rule (the “2020 CRA Final Rule” or the “Rescinded Rule”) in December 2021 and has since been operating under a CRA framework largely based on the OCC’s 1995 CRA rule (the “1995 Rule”), which was adopted jointly with the Federal Reserve and the FDIC. … Continue Reading

With Democrats now firmly in control of the FDIC, Acting Chairman Martin Gruenberg released a list of the FDIC’s priorities for 2022.  His list of priorities included the following:

  • Community Reinvestment Act (CRA): The FDIC, Federal Reserve, and OCC plan to act jointly on a notice of proposed rulemaking in the near future that would strengthen and enhance CRA. 
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Mr. Hunt shares his perspective on a range of issues, including how Rohit Chopra, CFPB Director-nominee, is likely to approach his new role, the CFPB’s likely approach to innovation and overdraft rulemaking under Mr. Chopra’s leadership, how banks are engaging with data aggregators, the OCC’s role and expectations for a new Comptroller, the status of Community Reinvestment Act rulemaking, and the potential for legislative changes.… Continue Reading

On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations.  This is the second in a series of five blog posts about the final rule.

The final CRA rule is an effort by the OCC to provide objective measures to evaluate the CRA performance of national banks and savings associations supervised by the OCC (including federal and state-chartered savings associations and uninsured federal branches of foreign banks). … Continue Reading

On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations.  According to the agency’s press release, the final rule is designed to increase CRA-related lending, investment and services in low- and moderate-income (“LMI”) communities where there is significant need for credit, responsible lending, and greater access to banking services. … Continue Reading

The OCC has issued a final rule revising its regulation implementing the Community Reinvestment Act (CRA).  The final rule applies to national banks and federal savings associations.

Although the OCC’s proposed revisions were issued jointly with the FDIC, the FDIC did not join in the final rule.  FDIC Chairman Jelena McWilliams issued a statement in which she indicated that although the FDIC continues to support CRA reform, “the agency is not prepared to finalize the CRA proposal at this time.” … Continue Reading

We are joined by Kenneth Thomas, who is widely-viewed as the nation’s leading CRA expert and has advised federal regulators on CRA reform.  After reviewing CRA’s origins and previous reforms, Ken shares his views on the current OCC/FDIC proposed changes, including why reform is a White House priority, differences in perspectives among CRA regulators, the proposal’s deposit-based approach to assessment areas and performance standards for larger banks, using a phased-in approach to reform, and the Presidential election’s impact on reform.… Continue Reading

The House Financial Services Committee has announced that it will hold the following hearings this month:

  • On January 14, the Subcommittee on Consumer Protection and Financial Institutions will hold a hearing entitled, “The Community Reinvestment Act: Reviewing Who Wins and Who Loses with Comptroller Otting’s Proposal.”  (On January 29, from 12 p.m.
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While banks, community groups, and regulators all seem to agree that there is a need to reform the Community Reinvestment Act (the “CRA”), which was signed into law by Jimmy Carter back in 1977 and hasn’t received a major update since the Clinton administration, there is significant disagreement over whether or not the recently proposed changes represent a path forward toward modernization and simplicity or a path backward toward discrimination and exclusion. … Continue Reading