community reinvestment

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

In this podcast, Diego Zuluaga, a Cato Institute policy analyst, joins us for a discussion of the CRA’s history, its effectiveness in increasing access to credit and addressing discrimination, the role of community groups, calls to expand CRA coverage to credit unions and fintech lenders, how regulators are approaching CRA reform, and creating a system of tradeable obligations to simplify compliance.… Continue Reading

On Monday, September 9, 2019, a group of 28 housing, consumer protection and community development organizations issued a letter to the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and Federal Reserve Board in advance of an anticipated Notice of Proposed Rulemaking regarding the Community Reinvestment Act (“CRA”) and in response to an Advance Notice of Proposed Rulemaking published in August 2018 (the “ANPR”).… Continue Reading

On July 31, 2019, the Office of the Comptroller of the Currency (the “OCC“) released OCC Bulletin 2019-40 (the “Bulletin”) detailing guidelines for national banks, federal savings associations and federal branches of foreign banking organizations subject to the Community Reinvestment Act (the “CRA”) requesting designation as a wholesale or limited purpose bank under the CRA or otherwise requesting confirmation as a special purpose bank pursuant to CRA regulations.… Continue Reading

The Federal Reserve Board has issued a report, “Perspectives from Main Street: Stakeholder Feedback on Modernizing the Community Reinvestment Act,” that summarizes the feedback it received during a series of roundtable discussions on the current state of, and potential revisions to, the Community Reinvestment Act (CRA).

Last August, the OCC issued an advance notice of proposed rulemaking (ANPR) in which it invited public comment in an effort “to solicit ideas for building a new framework to transform or on ways to transform or modernize the regulations that implement the [CRA].’” … Continue Reading

The Office of the Comptroller of the Currency (OCC) has issued an advance notice of proposed rulemaking (ANPR) on which it invites public comment “to solicit ideas for building a new framework to transform or on ways to transform or modernize the regulations that implement the Community Reinvestment Act of 1977 (CRA).” … Continue Reading