Archive

OCC SMALL BANK CRA GUIDE

With the publication of OCC Bulletin 2020-86 the Office of the Comptroller of the Currency (OCC) released: A compliance guide for small banks; An initial illustrative list of qualifying activities; and A form to request consideration of items to be added to the list of qualifying activities. The OCC’s website includes these items and other information regarding the OCC’s new CRA regulation […]

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FRB ISSUES ANPR FOR CRA

On September 21, 2020, the Federal Reserve Board of Governors (FRB) released an Advanced Notice of Proposed Rulemaking (ANPR) that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks. The ANPR has a 120-day comment period that begins once the ANPR is published in the Federal Register. The FRB’s ANPR stands in contrast to the final CRA regulations published by the Office of the Comptroller […]

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ARE REGULATORS RENEGING ON CRA PROMISES?

On March 19, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) published a Joint Statement of Policy (SOP) promising favorable consideration of retail banking services and retail lending activities in a financial institution’s assessment areas that are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected […]

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SO WHERE IS CRA HEADED NOW?

News has been leaking all week, now it is official: The Office of the Comptroller of the Currency (OCC) is publishing a final Community Reinvestment Act (CRA) rule today; Comptroller of the Currency Joseph Otting is resigning tomorrow; and The Federal Deposit Insurance Corporation is not joining the final CRA rule at this time. That leaves many unanswered questions, including what happens next to CRA? […]

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CRA CONSIDERATIONS FOR CORONAVIRUS ACTIVITIES

On March 19, 2020 the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a joint statement of policy regarding CRA Considerations for Coronavirus Activities. The Agencies recognize the potential for Coronavirus Disease (also referred to as COVID-19) to adversely affect the customers and operations of financial institutions. The agencies recognize that such efforts—when […]

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