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Community Reinvestment Act Update

OnDemand Webinar (86 minutes)

Gain a better understanding of where CRA will ultimately emerge and inform the next several decades of regulation.The outcome of a CRA Examination may impact your bank's ability to expand its operations or merge with other institutions and may affect the perception of your institution in the community. Successful CRA Exams require planning, recordkeeping and follow-up. In August 2018, the OCC published an Advance Notice of Proposed Rulemaking entitled Reforming the Community Reinvestment Act Regulatory Framework. The response of CRA stakeholders, including banks and bank trade associations, community groups and advocacy groups and state regulators, was overwhelming and reflected a variety of approaches. We expect that other federal regulators will inform the OCC's lead on the rulemaking and that proposed rules will be issued for comment in the final quarter of 2019 or the first quarter of 2020. This material will inform your understanding of where CRA will ultimately emerge and inform the next several decades of regulation.


John R. Mussman, Rimon P.C.


Overview-Sources: Statute, Regulation, Examination Manuals and Examination Reports of Peers

Current Regulation and Approach of Bank Regulators

• Regulation - What Goes Into CRA Rating

• How to Prepare for Examinations - Recordkeeping, Coordination of Compliance Officer, Lenders and Board and Bank Practices and Procedures

• CRA Reports by Regulators - Anticipating, Identifying and Responding to Examiner Concerns

• Regulatory and Other Effects of CRA Rating

• Appeals of Negative Rating

Modernization of CRA

• August 2018 OCC Publication - Solicitation of New Ideas and Response to OCC Questions

• Approximately 1500 Comments

• Approach of the Federal Reserve and FDIC

• Current Status of Modification and Reform - Proposed Regulations Expected in 4Th Quarter of 2019 or 1St Quarter of 2020

Alternative Approaches to CRA

• Redefinition of Assessment Area

• Use of Nontraditional Channels for Lending and Investment

• Investments in Indian Country and Other Communities With Low- and Moderate-Income Populations