The OCC issued News Release 2021-133 on December 14, 2021, announcing the final rescinding of their June 2020 Community Reinvestment Act (CRA) Rule.
The Final Rule will become effective as of January 1, 2022 and will apply to all national banks as well as to both federal and state savings associations. Financial institutions regulated by the OCC will revert back to the CRA rules adopted jointly by the Federal Banking Agencies in 1995. This includes the CRA Public File and CRA Lobby Notices, but moving back to those requirements will not be mandatory until April 1, 2022.
When the OCC announced back on September 8, 2021 a proposed rule to rescind their June 2020 Community Reinvestment Act (CRA) Rule, the announcement left many institutions confused with size determination, data collection requirements and processes that should be implemented to maintain compliance. There were aspects of the OCC June 2020 Community Reinvestment Act (CRA) Rule that had positive changes that would benefit a bank. Examples of these positive changes included a revision of total asset size threshold to determine when a bank was considered a large bank, applying a per-hour dollar rate for Community Development services, and providing a hotline to contact the OCC to determine if a loan, investment, or service would qualify as community development.
Now we play the waiting game for the OCC, FDIC, and FRB’s collaboration to develop a new, modernized CRA Rule to promote consistency for all insured depository institutions.
TCA recommends that when the proposed new CRA Rule is issued along with a comment period, financial institutions take the opportunity to comment and make recommendations on the CRA Performance evaluations, qualifications of Community Development activities, and expectations of meeting credit needs in the communities they serve. Many Non-Profit Organizations and Special Interest Groups will be commenting; financial institutions need to make themselves heard too!
Have questions or need assistance with your CRA program? Contact TCA to assist you in finding A Better Way to manage your CRA.
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