Wild Times for the Community Reinvestment Act
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In a move poised to reshape the regulatory landscape for U.S. banks, the Federal Deposit Insurance Corporation (FDIC) has signaled support for raising asset thresholds that determine the intensity of regulatory...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
The Federal Reserve Board has requested comment on a proposal designed to reduce the volatility of the capital requirements stemming from its annual stress tests. The proposal would achieve this primarily by averaging the...more
On April 15, the Treasury issued a direct final rule to eliminate several regulations or portions of regulations it deemed unnecessary in response to an Executive Order 14219 directing agencies to pursue deregulation. The...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
The House Financial Services Committee on March 5 took the first step toward repealing the CFPB’s overdraft rule, adopting a resolution under the Congressional Review Act. ...more
On October 30, two leading fintech industry trade associations submitted comments (see comment letters here and here) in response to a joint Request for Information (RFI) issued by the Office of the Comptroller of the...more
“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...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
This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more
This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more
On October 24, 2023, the Board of Governors of the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) approved long-awaited final...more
As we previously wrote in June, the Federal Deposit Insurance Corporation (“FDIC”) proposed amendments to the Deposit Insurance Fund (“DIF”) restoration plan originally adopted in September 2020 to implement a universal...more
As we previously reported, the CFPB is conducting an assessment of the TILA/RESPA Integrated Disclosure (TRID) Rule. Although the comment period associated with the Federal Register notice regarding the assessment ended on...more
Investors and investment managers around the globe are seeing increasing rules and regulations on how they can deploy their money, how they can advertise their services, and how they have to report to regulators. ...more
While banks, community groups, and regulators all seem to agree that there is a need to reform the Community Reinvestment Act (the “CRA”), which was signed into law by Jimmy Carter back in 1977 and hasn’t received a major...more
The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join...more