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CRA is not a game, but like playing a game once the rules are mastered results improve. This program explains the rules as they currently exist and explores the changes to the rules that are underway.
It has been years since the federal bank regulatory agencies have overhauled the Community Reinvestment Act regulations, but they are constantly tinkering with the rules.
During November 2017 the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies), published a final rule to amend their respective Community Reinvestment Act (CRA) regulations. The rule amended the definitions of “home mortgage loan” and “consumer loan” and the public file content requirements to conform to revisions made by the Consumer Financial Protection Bureau to its Regulation C, which implements the Home Mortgage Disclosure Act. The Agencies also made technical amendments to remove unnecessary cross references as a result of the amended definitions, and to remove an obsolete reference to the Neighborhood Stabilization Program. The revisions were effective on January 1, 2018.
On September 5, 2018 the OCC published an advanced notice of proposed rulemaking (ANPR) to modernize the CRA regulations. A new CRA regulatory framework would help regulated financial institutions more effectively serve the convenience and needs of their communities by encouraging more lending, investment, and activity where it is needed most; evaluating CRA activities more consistently; and providing greater clarity regarding CRA-qualifying activities. A transformed or modernized framework also would facilitate more timely evaluations of bank CRA performance, offer greater transparency regarding ratings, promote a consistent interpretation of the CRA, and encourage increased community and economic development in low- and moderate-income (LMI) areas. In addition, these types of revisions would align with the transformation of the banking industry and reduce the complexity, ambiguity, and burden associated with the regulations. The comment period on the ANPR closed on November 19, 2018. A Proposed Rule, issued jointly by all of the bank regulatory agencies, is expected in early 2020.
Bankers should view the current CRA ratings as a game. You need to learn how to play the game well. The challenge of playing the game is made more difficult as the agencies continuously change the rules of the game. This recording contains core knowledge needed by all lenders to comply with the current rule and to understand the direction in which the CRA regulations are headed. Also:
- The detailed manual is a great desktop reference; and
- The presenter has decades of experience with this topic.
This two-hour recording includes:
- A review of the basic requirements of CRA and its implementing regulations, including:
- Performance tests, standards, and ratings;
- Assigned ratings;
- Assessment area delineation;
- Public file requirements;
- CRA notices; and
- Community Development activities;
- An explanation of the annual adjustment to the asset-size thresholds used to define “small bank” and “intermediate small bank;” and
- An update on the status of the revisions of the CRA regulations.
The recording is designed for management of the loan department, Compliance Officers, CRA Officers, marketing staff and auditors.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 43 years. In 38 years as a trainer over 145,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.