The fatal flaws in the 2023 CRA rule
Predictions regarding the 2023 CRA Rule and Section 1071 and how to prepare for expected developments
How to estimate how your performance will look under the new CRA
2024 Regulatory Hot Topics
The Coming Perfect Storm
The Importance of Assessment Areas
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Keeping up with all the new regulations
What’s behind the increase in CRA Exam failures?
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
Dear Banker, Many bankers are easily confused by the technical requirements for loans in "disaster areas'' to be potentially qualified for community development credit under CRA. This brief article explains how to avoid...more
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The...more
On April 4, acting Comptroller of the Currency Michael J. Hsu provided his remarks for the second year in a row at the Just Economy Conference hosted by the National Community Reinvestment Coalition. He focused his remarks on...more
FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy. ...more
On March 21, the FDIC, Fed, and OCC jointly issued an interim final rule to extend the applicability date of certain provisions of the Community Reinvestment Act (CRA) final rule and requested comments on the extension. The...more
There has been much understandable confusion about many aspects of the new CRA rule. But perhaps there’s been no greater confusion and anxiety than about the Assessment Areas. And this anxiety has become more acute the closer...more
In July 2023, the Office of Management & Budget published an update to “Core Based Statistical Areas, Metropolitan Divisions, and Combined Statistical Areas”. That document contains the latest definitions of Metropolitan...more
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if...more
One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is "Community Development Lending". But while Community Development Lending is critically important, there is very little information...more
On October 24, 2023, representatives of the Treasury, the Federal Reserve, and the Federal Deposit Insurance Corporation released their final rule with respect to the Community Reinvestment Act (CRA), which is intended to...more
The Federal Deposit Insurance Corporation has announced that it is launching a new Banker Engagement Site (BES) this month through FDICconnect to serve as the primary tool for exchanging examination planning and other...more
As we reported in May, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed...more
On May 5, 2022, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together the Agencies) released a joint notice of proposed...more
Federal Banking Agencies Issue CRA Modernization Proposal The federal banking agencies have jointly issued a proposed rule that would modernize their regulations that implement the Community Reinvestment Act (the “CRA”). The...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more
On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. This is the second in a series of five blog posts about the final rule....more
"There are a few ways to obtain low-income housing tax credits. Each program has stress points in making it work, so there isn’t always a clear choice. Timing is often a decisive factor."...more
Treasury Provides Additional Clarity on Opportunity Zones by Issuing Second Round of Proposed Regulations - On April 17, 2019, the U.S. Department of the Treasury issued its second set of proposed regulations (the “New...more
The U.S. Department of the Treasury has issued a memorandum in which it makes recommendations to modernize the Community Reinvestment Act (CRA). ...more
Several federal agencies have issued reminders and requirements related to banking and credit services for borrowers affected by Hurricane Harvey. We previously reported on mortgage-related guidance issued by Fannie Mae,...more
This week, the Ferguson Commission released an analysis of the socio-economic environment following the shooting of Michael Brown that included recommendations for financially strengthening lower-income areas. The Commission,...more