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
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 light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more
The Federal Deposit Insurance Corporation (“FDIC"), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”) announced, that they intend to issue a proposal to...more
On March 28, the FDIC, the Fed, and the OCC announced their intention to issue a proposal to rescind the CRA final rule that was issued in October 2023 (covered by InfoBytes here). According to the prudential regulators, this...more
On March 28, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the federal banking agencies) announced their intent to rescind the...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 July 12, the FDIC, Fed, and OCC released a list of distressed or underserved nonmetropolitan middle-income areas eligible for CRA credit. The list identified regions where banks’ revitalization or stabilization activities...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...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 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 February 5, a group of trade, banking, and business associations filed a class-action complaint for injunctive relief against the OCC, Federal Reserve, and FDIC (the Agencies) for their enforcement of the new rulemaking...more
On October 24, 2023, the OCC, FDIC and Board of Governors of the Federal Reserve System jointly adopted final amendments to their regulations implementing the Community Reinvestment Act of 1977 (CRA). In this episode, which...more
After more than five years—with competing developments at times—the federal banking agencies (Federal Reserve, OCC, and FDIC) have revamped the regulations that implement the Community Reinvestment Act (CRA). The final...more
President Biden spent nearly 18 months assembling his team of top financial services regulators. Michael Barr’s nomination as the top banking regulator at the Federal Reserve Board (FRB) will fill the last remaining vacancy...more
As we previously reported, the Office of the Comptroller of the Currency (“OCC”) rescinded its 2020 Community Reinvestment Act (“CRA”) final rule (the “2020 CRA Final Rule” or the “Rescinded Rule”) in December 2021 and has...more
After moving alone in 2020 to reform its Community Reinvestment Act (CRA) regulation, the Office of the Comptroller of the Currency (OCC) has joined the Federal Deposit Insurance Corporation (FDIC) and Federal Reserve Board...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more
The Office of the Comptroller of the Currency (OCC) issued a proposal to rescind its June 2020 Community Reinvestment Act (CRA) rulemaking and replace it with previous rules jointly adopted by the OCC, the Federal Reserve...more
In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more
Division of Banks Warns of Risks from Representments Causing Multiple NSF Fees - The Massachusetts Division of Banks has issued a supervisory alert letter to warn banks about certain legal risks and risks of regulatory...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more
In This Issue. The Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac will no longer charge lenders the Adverse Market Refinance Fee; the Federal Deposit Insurance Corporation (FDIC) is seeking...more
In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more