2023 CRA Rule Repeal: Lessons to be Learned
The fatal flaws in the 2023 CRA rule
Predictions regarding the 2023 CRA Rule and Section 1071 and how to prepare for expected developments
How to estimate how your performance will look under the new CRA
2024 Regulatory Hot Topics
The Coming Perfect Storm
The Importance of Assessment Areas
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Keeping up with all the new regulations
What’s behind the increase in CRA Exam failures?
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
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
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its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule.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
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
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
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
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
On January 2, the OCC released its CRA performance evaluations that became public during the month of December. The OCC evaluated 16 entities, including national banks, federal savings associations, and insured federal...more
In 2024, the U.S. federal bank regulators were extremely active, with initiatives ranging from antitrust and capital to proposals regarding controlling shareholders and incentive-based compensation. Climate issues and...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 October 1, the OCC released its CRA performance evaluations for September. The OCC evaluated 21 entities, including national banks, federal savings associations and insured federal branches of foreign banks. The assessment...more
On September 3, the OCC released its Community Reinvestment Act (CRA) performance evaluations for August. The OCC evaluated 17 entities, including national banks, federal savings associations and insured federal branches 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
On June 3, the OCC released its Community Reinvestment Act (CRA) performance evaluations for May. The OCC evaluated 19 entities including national banks, federal savings associations, and insured federal branches of foreign...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
A federal district judge in Texas has enjoined federal bank regulators from enforcing the recently overhauled Community Reinvestment Act (“CRA”) rules. The injunction was issued on the eve of the first effective date under...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
Podcast #71 of The Compliance 911 Show discusses how banks can estimate their performance under the new Community Reinvestment Act (CRA) rules. Len highlights bankers' concerns about the increased difficulty in passing the...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
On March 1, the OCC released its Community Reinvestment Act (CRA) performance evaluations for last February. The OCC evaluated 31 national banks and federal savings associations under four ratings: Outstanding, Satisfactory,...more
On February 27, Michelle Bowman, a member of the Federal Reserve Board of Governors, gave a speech reflecting on the state of the broader U.S. economy and banking regulation in Tampa, Florida. Bowman highlighted the need for...more
On December 26, 2023, the OCC announced revisions to the asset-size thresholds used to define small and intermediate small banks and savings associations under the Community Reinvestment Act (CRA). Effective January 1, 2024,...more
On October 24, 2023, representatives of the Treasury, the Federal Reserve, and the Federal Deposit Insurance Corporation released their final rule with respect to the Community Reinvestment Act (CRA), which is intended to...more
The Fed, FDIC, and OCC have extensively revised rules implementing the Community Reinvestment Act (CRA), a 1977 law to encourage banks to help meet the credit needs of their communities, especially in low- and moderate-income...more