Wild Times for the Community Reinvestment Act
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There’s a very big inconsistency in the Community Reinvestment Act. The current CRA rule was passed in 1995 and requires every FDIC insured bank to meet the credit needs of the communities they serve. All “covered” banks are...more
On August 5, the FDIC released its list of state nonmember banks evaluated for CRA compliance, covering ratings assigned in May 2025. The FDIC released the ratings of 69 institutions, with 63 receiving a satisfactory rating,...more
TABLE OF CONTENTS: • President Trump Signs GENIUS Act Into Law • Joint Statement on Crypto Risk Management • Federal Agencies Propose Rescission of the 2023 Community Reinvestment Act Final Rule • FDIC Seeks Input...more
Federal bank regulators have released a proposal to rescind the Community Reinvestment Act (CRA) final rule that was issued in October 2023....more
Join top CRA experts Dr. Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act....more
On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more
The Trump Administration officially has announced it intends to emphasize “deregulation” with a focus of eliminating 10 regulations for every new regulation. Eliminating regulations is one thing, but enforcement is another...more
On July 1, the OCC released CRA performance evaluations for 22 national banks, federal savings associations, and insured federal branches of foreign banks, covering the period from June 1 through June 30. Of the evaluations...more
Bank regulators have announced their intention to repeal the 2023 CRA Rule. But it would be a mistake to stop there. For more than a decade there’s been a clamoring to “modernize” the CRA regulations. If the Administration...more
Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public...more
Now that the Trump Administration has announced its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule. It was unbelievably complex, confusing and...more
In January 2025, the new Trump administration issued Executive Order 14173, which ordered all executive departments and agencies to, among other things, end federal “diversity, equity, and inclusion” (DEI) programs and to use...more
In Podcast 95, Len and Dean argue that the 2023 CRA rule is flawed and confusing, urging its repeal and calling for reforms that truly support community development....more
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
Dear Banker, Many bankers are easily confused by the technical requirements for loans in "disaster areas'' to be potentially qualified for community development credit under CRA. This brief article explains how to avoid...more
In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I...more
In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more
In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule: 1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment...more
What Happened? The Federal Deposit Insurance Corporation (“FDIC”), Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Office of the Comptroller of the Currency (“OCC”), (collectively, “federal...more
Len & Dean examine how the 2023 CRA rule and Section 1071 could impose unrealistic standards on banks through rigid assessment areas, urging the industry to engage in the rulemaking process and prepare for regulatory changes...more
On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices,...more
The federal banking agencies have announced their intent to issue a proposal to rescind the Community Reinvestment Act (CRA) final rule originally issued in October 2023. In their announcement on March 28, the agencies also...more
Today, March 28, the regulators announced what many have been anticipating. The Agencies issued a press release indicating they intend to rescind the 2023 CRA rule....more
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is...more