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 of the Currency (OCC) on May 20, 2020.

  • The OCC’s final rule is effective October 1, 2020.
  • The FRB’s rule is far from complete.
  • The Federal Deposit Insurance Corporation joined the OCC on a proposed rule, but did not join the OCC on the final rule. It is not clear at this time the direction in which the FDIC is headed.

The chances that all three agencies will settle on a single regulation applicable to all financial institutions diminish significantly if the OCC does not delay implementation of its final regulation.
 

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