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The CRA was enacted in 1977 to ensure that each insured depository institution serves the convenience and needs of its entire community, including low and moderate-income (“LMI”) neighborhoods, consistent with its safe and sound operation. This mission is the essence of what community banks do.
In 2022 the OCC, FDIC, and Federal Reserve Board published a notice of proposed rulemaking outlining a new CRA framework. We view some aspects of the proposal, including the increased asset thresholds, a qualifying activities list and confirmation process, and the ability of small banks to opt-in to the new framework or continue to be evaluated under their current framework as beneficial to community banks.
However, we are concerned that the complexity of the new tests, in particular the Retail Lending Test, may increase the cost of compliance and make it more difficult to attain “high satisfactory” or “outstanding” ratings. We are also concerned that Retail Lending Assessment Areas (“RLAAs”) may cause larger community banks to reduce lending away from their branches in order to avoid triggering the creation of RLAAs.
|Comments on CRA Modernization Proposal||FDIC, Fed, OCC||08/05/22|
|CRA Comment Period Extension Request Banking Trades Joint Letter||FDIC, OCC||05/31/22|
|Joint Trades Letter to OCC Regarding 2020 CRA Rescission||OCC||10/29/21|
|OCC CRA Rule Recission ICBA Comment||OCC||10/29/21|
|Joint Letter on Withdrawing CRA Rule||OCC||05/03/21|
|ICBA's Comment Letter on Exemptions to SAR Report Requirements||OCC, FDIC||02/23/21|
|Letter Regarding CRA Information Collection Survey||OCC||02/16/21|
|ICBA Comment Regarding CRA Advance Notice of Proposed Rulemaking||FRB||02/16/21|
|ICBA OCC CRA Benchmarks NPR Comment - 2021||OCC||01/21/21|
|Request to Withdraw CRA Information Collection||OCC||01/11/21|
|ICBA Letter Regarding CRA - April 8, 2020||FDIC, OCC||04/08/20|
|National Banking Trades Letter Regarding CRA Comment Deadline||FDIC, Office of the Comptroller of the Currency||01/15/20|