Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]
Category: CRA
2015 LENDING COMPLIANCE THRESHOLDS
Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2105 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion. The term “intermediate small bank” means a small […]
PROPOSED REVISIONS TO INTERAGENCY CRA QUESTIONS AND ANSWERS
The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies) are proposing to clarify their Interagency Questions and Answers Regarding Community Reinvestment to address several community development issues. The Questions and Answers were first published under the auspices of the Federal Financial Institutions Examination Council (FFIEC) in 1996, and were last revised on March 11, 2010. The Agencies propose to: Revise five questions and answers, […]
NEW CRA ASSET-SIZE THRESHOLDS
On December 19 the Federal Reserve Board published the new Community Reinvestment Act (CRA) asset-size threshold adjustments for small and intermediate small institutions. The adjustments are based on the change in the average of the Consumer Price Index (CPI) for urban wage earners and clerical workers, not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million. As a result of the 2.23 percent increase in the CPI index for […]
BLURRED LINES BETWEEN CRA AND FAIR LENDING
The Department of Justice’s Civil Rights Division, with it’s beefed up staff and budget, is actively pursuing fair lending issues. Several recent cases are blurring the lines between the Community Reinvestment Act (CRA) and the Fair Housing and Equal Credit Opportunity Acts. The purpose of CRA is to encourage banks to meet the credit needs of their local communities. The level of encouragement has increased significantly over the years. The Department of Justice (DOJ) has […]