OCC benchmarking proposal

The fate of the OCC’s Community Reinvestment Act (“CRA”) final rule, issued on May 20, 2020, hangs in the balance following the inauguration of President Biden on January 20 and the resignation of former Acting Comptroller Brian Brooks, who was a major proponent of the rule, on January 14.

Although the OCC’s CRA final rule technically became effective on October 1, 2020, it provides transition periods for compliance based on a bank’s asset size, type of charter, and business model.… Continue Reading