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
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
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
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
Recently, the OCC released data on small business, small farm, and community development lending during 2023, compiled by the FFIEC. The 2023 data, reported by 721 lenders, revealed a slight increase in reporting institutions...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
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
Recently, the OCC released its Community Reinvestment Act (CRA) performance evaluations for June. The OCC evaluated 21 entities, including national banks, federal savings associations, and insured federal branches of foreign...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
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 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
On February 5, 2024, several national and Texas banking and business trade groups (Plaintiffs) filed a lawsuit challenging the final regulations (Final Rules) implementing the Community Reinvestment Act of 1977 (CRA) that...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many bankers, although not...more
Banking agencies are alleged to have exceeded their congressional authorization, with potentially adverse consequences on banks and consumers. On February 5, 2024, several banking trade groups[1] (the Plaintiffs) sued...more
The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more
On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks...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, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations...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
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
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
On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more
On October 24, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued a final rule amending their regulations implementing the...more
At its open Board meeting scheduled for October 24, 2023, the Federal Reserve Board is expected to approve its final rule amending its current regulation implementing the Community Reinvestment Act....more