BROADCAST EMAIL – Regulatory Update

On December 12^th,the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation jointly released a notice of proposed rulemaking to be published in the Federal Register to revise the Community Reinvestment Act (CRA) regulations.

According to a statement released by the two agencies, the banking industry has changed dramatically since the law’s enactment in 1977 and because major changes to the regulation were last made in 1995, FDIC and OCC agree that the current CRA framework has not kept pace with such changes, which can adversely affect the very communities CRA was intended to protect.  In addition, according to the two agencies’ statements, the proposed rule would strengthen the CRA regulations by (1) clarifying which activities qualify for CRA credit; (2) updating where activities count for CRA credit; (3) creating a more transparent and objective method for measuring CRA performance; and (4) providing for more transparent, consistent, and timely CRA-related data collection, recordkeeping, and reporting. Publication of the proposed rule has been anticipated due to concerns that changes to CRA could decrease the footprint of banks in the affordable housing arena, particularly investment in Housing Credits.

There will be a 60-day comment period on the rule from the date it is published in the Federal Register (expected publication is this week). CARH will review the proposed rule and provide comments to FDIC and OCC.

The proposed changes will also be discussed during CARH’s 2020 Midyear Meeting in New Orleans, Louisiana. If you have and comments or concerns that you would like CARH to consider including in our final comments, please forward them to carh@carh.org no later than February 1, 2020.