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Community Reinvestment Act Reporting Requirements Regulatory Requirements

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The Community Reinvestment Act Big Secret

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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

Orrick, Herrington & Sutcliffe LLP

FDIC and OCC release CRA evaluations for May and July of 2025, respectively

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

GeoDataVision

Potential Improvements for CRA (Part 4c of 4)

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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

GeoDataVision

Potential Improvements for CRA (Part 4b of 4)

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In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more

GeoDataVision

Potential Improvements for CRA (Part 4a of 4)

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In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule: 1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its December CRA evaluations

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

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

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In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

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