On August 28, 2018, the Office of the Comptroller of the Currency (“OCC”) released an advanced notice of proposed rulemaking (“ANPR”) inviting comments on a revised Community Reinvestment Act (“CRA”) framework. In the ANPR, the OCC described its vision for a new CRA framework that would:

  • encourage more lending and investment activity in low and moderate income communities;
  • provide more consistency across CRA evaluations and ratings; and
  • promote clarity regarding CRA-qualifying activities.

The ANPR requests responses to 31 questions across several topic areas, including the current CRA regulatory approach; a modernized CRA regulatory approach; CRA-qualifying activities; and recordkeeping and reporting.


Continue Reading OCC Releases Advanced Notice of Proposed Rulemaking Regarding CRA Framework

On April 3, 2018, the Department of the Treasury (“Treasury”) released its much-anticipated recommendations to reform the Community Reinvestment Act (“CRA”). The report, which is addressed to the federal banking agencies, outlines a number of proposed regulatory and administrative changes to (i) the CRA’s performance evaluation criteria, and (ii) the federal banking agencies’ approach to