The Community Reinvestment Act Proposal: Amending and Modernizing CRA Regulations
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Key takeaways:
- On May 5, 2022, the Federal Reserve Board, Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency issued a notice of proposed rulemaking (the “Proposal”) that would amend the regulations implementing the Community Reinvestment Act of 1977 (the “CRA”). The Proposal, the first significant interagency revisions since 1995, seeks to revise the CRA regulations to account for changes in the banking industry, including the growth of online banking.
- In this Client Update we provide a summary of the Proposal’s key elements, which include: (1) changes to the asset threshold of the different bank categories; (2) changes to the activities that qualify for CRA credit; (3) new types of assessment areas that allow for increased flexibility in obtaining CRA credit; (4) revisions to the evaluative framework with respect to grading scale, performance tests and strategic plan process; and (5) new data collection and reporting obligations.
- Comments on the Proposal are due by August 5, 2022.