REVISED INTERAGENCY CRA QUESTIONS AND ANSWERS

Recently the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); Federal Deposit Insurance Corporation (FDIC) published final revisions to the Interagency Questions and Answers Regarding Community Reinvestment. The final rule was based on a proposal issued on September 10, 2014 that addressed alternative systems for delivering retail banking services; community development-related issues; and the qualitative aspects of performance, including innovative or flexible lending practices and the responsiveness and innovativeness of an institution’s loans, qualified investments, and community development services.

The 220-page rule clarifies nine of the 10 proposed questions and answers (Q&A), revises four existing Q&As, and adopts two new Q&As. The Agencies did not adopt one of the proposed revisions to guidance that addressed the availability and effectiveness of retail banking services. All of the new and revised Q&As, as well as those Q&As that were published in 2010 and 2013 and that remain in effect are in the final guidance.

The final rule is effective upon publication in the Federal Register, which is expected soon.

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