Tag Archives: Community Reinvestment Act

FRB Governor Brainard Discusses Path Forward on Community Reinvestment Act Reform

On January 8, 2020, Federal Reserve Board (“FRB”) Governor Lael Brainard delivered remarks on the state of Community Reinvestment Act (“CRA”) reform before an audience at the Urban Institute.  As we summarized in a client alert, last month, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) released … Continue Reading

FDIC and OCC Propose Major Overhaul of Community Reinvestment Act Regulations

On December 12, 2019, the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC”) released a notice of proposed rulemaking to overhaul the agencies’ regulatory framework for evaluating banks’ Community Reinvestment Act (“CRA”) performance.  The proposal follows a 2018 advance notice of proposed rulemaking by the OCC, … Continue Reading

Agency Heads Speak on CRA Reform

In the past few weeks, both Federal Deposit Insurance Corporation (“FDIC”) Chairman Jelena McWilliams and Comptroller of the Currency Joseph Otting have spoken publicly about ongoing efforts by their agencies, and by the Federal Reserve Board, to reform regulations implementing the Community Reinvestment Act (“CRA”). The federal bank regulatory agencies have been working on reforms … Continue Reading

Governor Brainard Discusses Financial Inclusion, Fintech, and Reforms to the Community Reinvestment Act

On October 17, 2018, Federal Reserve Board Governor Lael Brainard discussed the potential for financial innovation, and in particular, fintech products and services, to foster financial inclusion of underserved families and small businesses.  She has frequently addressed the importance of fintech, including cryptocurrencies, digital currencies and distributed ledger technologies and the role of banks in … Continue Reading

OCC Issues Guidance on CRA Ratings Downgrades for Consumer Compliance Violations

On October 12, 2017, the Office of the Comptroller of the Currency (“OCC”) issued a Policies and Procedures Manual (“PPM”) outlining the framework to be used by examiners to determine whether an OCC-regulated bank should receive a downgrade of its Community Reinvestment Act (“CRA”) performance rating based on evidence of discriminatory or other illegal credit … Continue Reading
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