Archive

AGENCY CRA MANEUVERS

There has been recent activity on the proposed Community Reinvestment Act (CRA) regulations, but it is not clear whether the process is moving in a positive direction or not. Brainard Explains FRB Position The Federal Reserve Board (FRB) decided not to join the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Company (FDIC) in issuing the proposed revisions to the CRA regulations. On January 8, 2020 FRB Governor Lael Brainard […]

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ARE YOU LIBOR READY?

Many financial institutions make consumer loans, residential mortgage loans, and commercial loans with pricing based on the London Inter-Bank Offered Rate (LIBOR). In 2017 the United Kingdom’s Financial Conduct Authority (the regulator that oversees the LIBOR panel) announced that, by the end of 2021, it will discontinue the index. The Federal Reserve Board of Governors and the Federal Reserve Bank of New York (FRBNY) in conjunction with the U.S. Treasury Department’s Office of Financial Research have […]

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CRA THRESHOLD ADJUSTMENT

On December 30, 2019 the OCC, the Board, and the FDIC (collectively the Agencies) amended their Community Reinvestment Act (CRA) regulations to adjust the asset-size thresholds used to define ” small bank” or “small savings association” and “intermediate small bank” or “intermediate small savings association.” As required by the CRA regulations, the adjustment to the threshold amount is based on the annual percentage change to the Consumer Price Index for Urban Wage Earners and Clerical […]

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CRA PROPOSAL

On December 12, 2019 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) announced a proposal to modernize the regulations under the Community Reinvestment Act (CRA) that have not been substantively updated for nearly 25 years. The proposed rules are intended to increase bank activity in low- and moderate-income communities where there is significant need for credit, more responsible lending, greater access to banking services, and improvements to […]

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REGULATORS UNABLE TO AGREE ON FUTURE OF CRA

Like kids in a sandbox the regulators cannot agree on the rules of the game being played. In this case the game is the Community Reinvestment Act. The implementing regulations and examinations procedures have been in serious need of revisions for 25 years. The agencies seem to agree that changes are needed, they just can’t agree on the direction of the change. Last year Comptroller of the Currency Otting jumped the gun and published an […]

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