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
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
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
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
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
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
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The...more
During the Biden-Harris Administration, the relationship between financial institutions and their regulators chilled considerably. The financial services industry works daily with its regulators—especially through the...more
While the coming weeks and months will provide more clarity, we already can anticipate some indications of what is in store for bank regulation, supervision, and enforcement in a second Trump Administration. To help navigate...more
When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it...more
On October 3, the FDIC released an updated list of state nonmember banks examined for compliance under the CRA. The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 requires public disclosure of...more
On August 5, the FDIC released an updated list of banks evaluated for compliance with the CRA in May, June, July and August. In May, the FDIC disclosed a list of evaluations of 56 banks, of which two were rated “outstanding,”...more
On July 18, the OCC, FDIC, and the Fed (the federal banking agencies or FBAs) submitted a brief requesting that the U.S. Court of Appeals for the Fifth Circuit hold oral argument and reverse the U.S. District Court for the...more
Headlines 1. Supreme Court Upholds the Constitutionality of the CFPB’s Funding Structure The Supreme Court has ruled that the statutory authorization that allows the CFPB to draw funds from the earnings of the Federal Reserve...more
FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy. ...more
On March 21, the FDIC, Fed, and OCC jointly issued an interim final rule to extend the applicability date of certain provisions of the Community Reinvestment Act (CRA) final rule and requested comments on the extension. The...more
The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more
The SEC has issued a controversial 886-page final rule imposing climate-related disclosure requirements on publicly traded companies, including banking organizations, which will require them to include certain climate-related...more
On March 8, the Fed, OCC, and FDIC (the federal banking agencies, or “FBAs”) submitted a brief opposing the plaintiffs’ motion for a preliminary injunction to stop the CRA final rule from going into effect. As previously...more
On March 4, the FDIC released a list of state nonmember banks evaluated for compliance with the Community Reinvestment Act (CRA) for March. The FDIC evaluated 56 banks with four ratings: Outstanding, Satisfactory, Needs to...more
Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community...more
As discussed here, on October 24, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency finally issued their long-awaited final rule modernizing how they...more