Like kids in a sandbox the regulators cannot agree on the rules of the game being played. In this case the game is the Community Reinvestment Act. The implementing regulations and examinations procedures have been in serious need of revisions for 25 years. The agencies seem to agree that changes are needed, they just can’t agree on the direction of the change. Last year Comptroller of the Currency Otting jumped the gun and published an […]
Category: CRA
OCC ISSUES CRA GUIDELINES
On July 31 the Office of the Comptroller of the Currency issued guidelines for requesting: Approval of a strategic plan (OCC Bulletin 2019-39); and Designation as a wholesale, limited purpose, or special purpose bank (OCC Bulletin 2019-40).
HAS REDLINING ENFORCEMENT RETURNED?
At the end of the Obama administration redlining consent decrees were becoming coming. Redlining cases, once the purview of large banks, had drifted down to the community bank level. Since the beginning of 2016 redlining cases have dried up, other than one case left over from the prior administration that was settled favorably for the bank. On June 13, 2009 The Department of Justice (DOJ) and the U.S. Attorney’s Office for the Southern District of […]
STATUS OF CRA REVISIONS
The federal banking regulatory agencies are making progress in development of a proposal to revise the Community Reinvestment Act regulations. Senior officials at the Office of the Comptroller of the Currency, Federal Deposit Insurance Corp. and Federal Reserve briefed industry leaders on the topic at a recent Consumer Bankers Association conference. The officials indicated that, after preliminary talks and a review of public comments submitted to the OCC, the agencies are ready to start writing […]
RURAL REMINDERS
2019 list of rural and underserved counties The Consumer Financial Protection Bureau (CFPB) has published the 2019 list of rural and underserved counties and a separate 2019 list that includes only rural counties. The CFPB has also updated the Rural and Underserved Areas Tool (Tool) for 2019. The lists and the tool help creditors determine whether a property is located in a rural or underserved area for purposes of applying certain regulatory provisions related to mortgage loans. […]