Wednesday, July 28, 2021
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2021 CRA Review & Update, OKC

September 16 @ 8:30 am - 4:00 pm CDT

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It has been years since the federal bank regulatory agencies have overhauled the Community Reinvestment Act (CRA) regulations. Right now, major revisions are unfolding, but in an awkward manner.

• On December 12, 2019 the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released a Notice of Proposed Rulemaking (NPR) intended to increase bank activity in low- and moderate-income communities where there is significant need for credit, more responsible lending, greater access to banking services, and improvements to critical infrastructure.

• On May 20, 2020, the OCC approved a final rule to modernize the CRA regulations. The final rule was effective on October 1, 2020, but it will be several years before national banks have to fully implement the regulations.

• On September 21, 2020 the Federal Reserve Board (FRB) released an Advanced Notice of Proposed Rulemaking that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks.

• On May 18, 2021, the Office of the OCC published OCC Bulletin 2021-2, which states that the OCC has determined that it will reconsider the final CRA Rule published on June 5, 2020. This is a major step towards achieving uniform revised CRA regulations.

• At present the FDIC, the OCC and the Federal Reserve Board are united in the belief that major revisions to the CRA regulations are needed, but all three agencies are headed in different directions.

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