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All in CRA
In this Compliance Clip (video), Adam briefly discusses the recent CRA proposal by providing an overview of the goals of the proposal. Adam also discusses how, if passed as proposed, this new rule would have some major changes to Assessment Areas that may have negative effects on banks. Comments are due soon on this proposal, so watch this video to learn how the changes might affect your bank.
The long awaited CRA proposal was published in the Federal Register on January 9, 2020, meaning that comments on the proposed rule are due on March 9, 2020. This joint proposal between the OCC and FDIC did not include the support of the Federal Reserve, who currently have a slightly different take on how CRA regulations should be revised (according to comments by Federal Reserve Governor Lael Brainard on January 8, 2020). As we have explained before, this would be the first substantial update to the rules in nearly 25 years if the rule is finalized. According to the release, the proposed rules are intended to do a number of things including:
As is the case each year, the regulatory agencies have adjusted the asset size threshold under the Community Reinvestment Act for 2020. The “small institution” asset threshold has increased from 1.284 billion to 1.305 billion, while the “intermediate small institution” asset threshold has increased from 321 million in 2019 to 326 million in 2020.
On December 12, 2019, the FDIC and OCC announced a long-awaited proposal to modernize the regulations under the Community Reinvestment Act (CRA). If finalized as proposed, this would be the first substantial update to the rules in nearly 25 years. According to the release, the proposed rules are intended to do a number of things including…
In this Compliance Clip (video), Adam reviews the items needed to be in the CRA public file of each bank. As the CRA public file must be current as of April 1 of each year, banks can use this video to review their public file and ensure they have everything they need.
As explained in this video, certain information must be kept in each bank’s CRA public file. The following is section 228.43 from Regulation BB, which…
The FDIC and OCC have each released their lists of CRA performance evaluations from August 2018. In addition, these agencies - as well as the Federal Reserve - have released their quarterly schedules of planned CRA evaluations for the 4th quarter of 2018 and the first quarter of 2019. Institutions regulated by the OCC, FDIC, and Federal Reserve can review these schedules to determine whether they are on the planned list of upcoming CRA exams. As we have said before, one of the best
On August 28, 2018, the Office of the Comptroller of the Currency (OCC) issued an advance notice of proposed rulemaking (ANPR) inviting public comment on ways to modernize the regulations that implement the Community Reinvestment Act (CRA). In their notice (OCC-2018-0008), the OCC is soliciting ideas on how the CRA rules could better achieve the statute’s original purpose, encourage increased lending and investment where it is needed the most, and reduce the burden associated with reporting and evaluating CRA performance. As the OCC plans to share the results of the ANPR with other regulatory agencies, all financial institutions are encouraged to provide comments to the OCC.
Compliance requirements for CD secured loans are not typically a huge topic of discussion for compliance seminar speakers or article authors. That said, one of our members suggested this topic (you know who you are!), and I think it is a great topic to write on from the perspective of CD secured loans, rather than just bringing up these loans when discussing applicable regulations (which is usually the way it happens). The truth is that most financial institutions (and regulators) just…
Each month, the FDIC and OCC each release a list of banks that have been evaluated under the Community Reinvestment Act (CRA). This information is extremely valuable to CRA officers as one of the best ways to understand the CRA requirements for a financial institution is to read the performance evaluations of other financial institutions of the same regulator. This article summarizes some of the key points from these evaluations.
Last week, the OCC and FDIC released their monthly list of CRA ratings from June of 2018. The following summary provides a few noteworthy highlights from this months ratings. As we have advocated before, one of the best ways for a financial institution to understand their requirements under the Community Reinvestment Act (CRA) is to read the performance evaluations from other financial institutions.
