The FDIC’s and OCC’s Proposed CRA Reform: What You Need to Know

Signed into law by President Jimmy Carter in 1977, there has been no major update to the Community Reinvestment Act (CRA) since the Clinton administration. That is soon to change, with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation having recently issued a joint proposal to significantly revise their CRA regulations.

In this webinar, we will take a close look at what’s in the joint proposal. Topics will include:

• The proposal’s qualifying activities criteria and expansion of qualifying community development activities, including proposed changes to the “small business loan” criteria
• How the proposal would change a financial institution’s delineation of its assessment area, including how a bank with a significant portion of retail deposits outside of its facility-based locations would delineate its assessment area
• How CRA performance would be measured for small banks and under the general performance standards
• What “presumptive ratings” means and how such ratings would work
• The Federal Reserve’s position on CRA reform and why it didn’t join the proposed rulemaking
• What we think the proposal gets right or wrong