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After moving alone in 2020 to reform its Community Reinvestment Act (CRA) regulation, the Office of the Comptroller of the Currency (OCC) has joined the Federal Deposit Insurance Corporation (FDIC) and Federal Reserve Board in issuing a joint notice of proposed rulemaking setting forth proposed amendments to their regulations implementing the CRA. … Continue Reading

Expansion of CRA coverage.  On November 1, New York Governor Hochul signed into law amendments (S.5246-A/A.6247-A) to the New York Community Reinvestment Act (NYCRA) that expand the NYCRA’s coverage to non-depository mortgage lenders.  The amendments are effective November 1, 2022.  New York now joins a small group of states, including Illinois and Massachusetts, that apply CRA-type laws to non-depository mortgage lenders.… Continue Reading

When the OCC issued its final Community Reinvestment Act (“CRA”) rule on May 20, 2020, the agency acted alone without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued its proposed rule. The FDIC declined to join the OCC’s CRA reform effort, despite seemingly being in lock-step with the OCC up until that point.… Continue Reading

Over the past six weeks, opposition to the OCC’s Community Reinvestment Act (“CRA”) final rule has hardened on two fronts.  The OCC’s decision to hurriedly issue the final rule on May 20, 2020 without achieving consensus with the FDIC, the agency with which the OCC had jointly issued the proposed rule, has drawn the ire of both consumer advocacy groups and Congress.… 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

The OCC and FDIC announced yesterday that they have extended the 60-day comment period for their joint proposal to revise their regulations implementing the Community Reinvestment Act that was published in the Federal Register on January 8, 2020.  As extended by 30 days, the comment period ends on April 8, 2020.… Continue Reading

We are joined by Diego Zuluaga, a Cato Institute policy analyst, for a discussion of the proposed changes.  After reviewing the current regulatory framework, we examine the proposal’s new qualifying activities criteria and approach to “branchless banking” in determining assessment areas, respond to criticism of its approach to public projects, look at the small bank opt-out and what in the proposal should be revisited, and consider the impact of the Fed’s non-participation.… Continue Reading

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

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA).  Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join the proposal and presumably will issue a separate proposal.  Comments on the proposal are due by March 9, 2020.… Continue Reading

A memorandum issued by the Office of Management and Budget entitled “Guidance on Compliance with the Congressional Review Act” imposes a new review process on final rules issued by the CFPB and other independent regulatory agencies such as the Federal Reserve, the FCC, the FDIC, the FTC, and the OCC.  The new process will take effect on May 11, 2019.… Continue Reading