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Submit Comments to CRA Modernization Initiative

Several staff members of Thomas Compliance Associates (TCA) attended the recent CRA & Fair Lending Colloquium and obtained valuable information from the sessions. One theme that stood out and presenters stressed was that bankers can help shape the re-write of the Community Reinvestment Act (CRA) regulation. The Office of the Comptroller of the Currency (OCC) posted an advance notice of proposed rulemaking (ANPR) on its website and encourages public comments on the modernization of CRA.

The OCC has taken the lead by issuing the ANPR; however, the OCC wants to hear comments from other regulators, bankers, vendors, non-profit organizations and special interest groups that focus on community development.

At the colloquium, other regulatory agencies expressed their commitment to being involved in the CRA modernization. Together they expressed a desire to make the CRA examination more transparent, add accepted community development activities and open the door to other possible activities for consideration when conducting a bank’s performance evaluation. It was stressed that this is not an OCC project; the OCC just initiated the project.

The ANPR lists 31 questions that include revamping the rating system, providing more clarity and guidance on acceptable community development activities and ensuring consistency in testing among the banking supervisory agencies. For instance, Question 13 is: “How could the current approach to delineating assessment areas be updated?” For example, being forced into including whole counties needs to be debated.

Think of the ANPR as a fact-finding endeavor that serves as the precursor to the official release of a modernized proposed CRA Regulation. It gives bankers a chance to be heard and an opportunity to guide and influence the regulation from the beginning before hard-fasten CRA provisions are reached. Comments are due November 19, 2018.

If you have any CRA questions or would like to discuss your thoughts on this matter, please feel free to reach out to TCA.

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