OCC Publishes Essential CRA Information

On June 5, 2020, the Office of the Comptroller of the Currency (OCC) published a final rule revising its Community Reinvestment Act (CRA) regulation. The revised rule, which applies to national banks, federal savings associations, and federal branches of foreign banking organizations that are subject to the OCC’s regulations under CRA, was effective on October 1, 2020. Since June, the industry has been waiting for additional information essential for implementing the final rule.

On January 29, 2021, the OCC published part of that essential information, as OCC Bulletin 2021-5, which includes the:

  • List that identifies a bank’s type based on asset size or business model for 2021. The size thresholds determine that a bank with assets::
    • Of $600 million or less is a small bank.
    • Greater than $600 million and equal to or less than $2.5 billion is an intermediate bank.
    • Greater than $2.5 billion is a general performance bank (GPB, or large bank).
  • List of the distressed and underserved areas where certain bank activities conducted in 2021 are eligible to receive Community Reinvestment Act (CRA) consideration.
  • Banking industry median hourly compensation value ($39.03) used for determining the dollar value of community development service activities during 2021.

Additional information from the OCC is still expected. More importantly, the three bank regulatory agencies – the OCC, the Federal Deposit Insurance Corporation, and the Federal Reserve Board need to sync up their respective CRA regulations.

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