Archive

UNUSUAL OCC FAIR ACCESS PROPOSAL ON FAST TRACK

On November 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a Notice of Proposed Rulemaking (NPRM) that ensures that larger national banks and Federal savings associations offer and provide fair access to financial services. This is a most unusual proposal What The NPRM: Is a response to campaigns by political advocates who seek to achieve policy objectives by pressuring banks to stop providing financial services to customers (engaged in a lawful […]

NEXT PIECE OF OCC CRA RULES PUBLISHED

On November 24, 2020, the Office of the Comptroller of the Currency (OCC) published a Notice of Proposed Rulemaking (NPRM) regarding the Community Reinvestment Act’s (CRA) general performance standards. The OCC published a final rule on May 20, 2020, with an October 1, 2020 effective date, to strengthen and modernize the agency’s regulations under the CRA to encourage banks to engage in more activities to serve the needs of their communities, particularly low- and moderate-income and other […]

INTERAGENCY STATEMENT ON LIBOR TRANSITION

On November 6, 2020, the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a Statement on Reference Rates for Loans. The statement reiterates that the agencies are not endorsing a specific replacement rate for LIBOR for loans. A bank may use any reference rate for its loans that the bank determines to be appropriate for its funding model and customer needs. However, the bank should […]

OCC SMALL BANK CRA GUIDE

With the publication of OCC Bulletin 2020-86 the Office of the Comptroller of the Currency (OCC) released: A compliance guide for small banks; An initial illustrative list of qualifying activities; and A form to request consideration of items to be added to the list of qualifying activities. The OCC’s website includes these items and other information regarding the OCC’s new CRA regulation

FRB ISSUES ANPR FOR CRA

On September 21, 2020, the Federal Reserve Board of Governors (FRB) released an Advanced Notice of Proposed Rulemaking (ANPR) that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks. The ANPR has a 120-day comment period that begins once the ANPR is published in the Federal Register. The FRB’s ANPR stands in contrast to the final CRA regulations published by the Office of the Comptroller […]