On December 30, 2019 the OCC, the Board, and the FDIC (collectively the Agencies) amended their Community Reinvestment Act (CRA) regulations to adjust the asset-size thresholds used to define ” small bank” or “small savings association” and “intermediate small bank” or “intermediate small savings association.” As required by the CRA regulations, the adjustment to the threshold amount is based on the annual percentage change to the Consumer Price Index for Urban Wage Earners and Clerical […]
Category: CRA
CRA PROPOSAL
On December 12, 2019 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) announced a proposal to modernize the regulations under the Community Reinvestment Act (CRA) that have not been substantively updated for nearly 25 years. The proposed rules are intended to increase bank activity in low- and moderate-income communities where there is significant need for credit, more responsible lending, greater access to banking services, and improvements to […]
REGULATORS UNABLE TO AGREE ON FUTURE OF CRA
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 […]
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 […]