News & Analysis as of

Community Reinvestment Act Lending

Sheppard Mullin Richter & Hampton LLP

Persisting Regulatory Uncertainty: Federal Regulators Delay New Community Lending Rules

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

GeoDataVision

The Answers to the CRA Questions Everyone is asking: What must we do on April 1?

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With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers....more

Ballard Spahr LLP

Trade groups file lawsuit in Texas federal court challenging final OCC/FDIC/Federal Reserve Community Reinvestment Act rules

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Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community...more

GeoDataVision

The new CRA: Surprises and Problems by Omission

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I have written a number of articles about the new CRA and the problems its requirements will impose on banks. But there are also problems posed by what the new Rule omits....more

GeoDataVision

The new CRA Rule: Confusion Reigns

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Our office has been inundated with inquiries about an aspect of the impact of the impending new CRA rule. As we have noted in previous articles there are mistakes and inconsistencies in the new CRA Rule, and some of these...more

GeoDataVision

2022 Community Development Report by State

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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

GeoDataVision

The Disastrous New CRA Rule: Part IV – Is the 80% Retail Lending Assessment Area Exemption Really a Break for Large Banks?

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Dear Banker, The new CRA Rule contains a "break" for Large banks that would exempt them from having to declare Retail Lending Assessment Areas ("RLAAs") for any calendar year in which the bank lends more than 80% of its home...more

GeoDataVision

The Disastrous New CRA: Part III – It’s worse than you think and which banks are hurt the most

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In Parts I and II I explained the devastating impact of the new CRA Rule and what the underlying reasons for that adverse impact are. In Part III I will touch upon what banks are most significantly impacted by the new Rule....more

Ballard Spahr LLP

The New CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 3

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This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

GeoDataVision

New CRA Rule is a Disaster for Banks Part II: Key Regulator says Goal was “to raise the bar for CRA performance”

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In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new Rule demonstrate that if...more

GeoDataVision

New CRA Rule is a Disaster for Banks: Part I – And the Numbers Prove it!

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With all the news stories circulating about the new CRA Rule, it's surprising that not one article has addressed the topic that should be the biggest story of all - the catastrophic implications for banks!...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 2

Ballard Spahr LLP on

This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Butler Snow LLP

Community Reinvestment Act Final Rule Update

Butler Snow LLP on

On October 24, 2023, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation issued a final rule to strengthen and modernize regulations implementing the...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - October 2023 - 2

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Cadwalader, Wickersham & Taft LLP

In Depth: Summary of Notable Comments to Federal Banking Agencies’ Interagency Proposal to Update Community Reinvestment Act Rules

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

Bradley Arant Boult Cummings LLP

Agencies Offer Regulatory Assistance in Disaster Affected Areas

On the first day of National Preparedness Month, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union...more

Ballard Spahr LLP

The OCC’s CRA Final Rule: Changes And Highlights

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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

Manatt, Phelps & Phillips, LLP

OCC Moves Forward Alone, Issues Final Community Reinvestment Act Rule

On May 20, the OCC issued its final rule intended to modernize and clarify the Community Reinvestment Act (CRA). The rule included the surprising footnote that the FDIC, which had joined as a partner in the Notice of Proposed...more

Ballard Spahr LLP

OCC and FDIC issue joint proposal to revise CRA regulations

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The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA).  Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join...more

Vedder Price

New OCC Guidance on Community Reinvestment Act (CRA) Ratings

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On October 12, 2017, the OCC issued OCC Bulletin 2017-40 announcing the release of its Policies and Procedures Manual 5000-43 (PPM 5000-43), which outlines the OCC’s policy and framework for how the agency determines...more

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