Dec 13, 2019
The OCC and FDIC have released their long-awaited
joint proposal to revise and update the Community
Reinvestment Act regulatory framework. In this bonus episode of the
ABA Banking Journal Podcast, sponsored by OneTrust
Vendorpedia, senior OCC policy official Grovetta Gardineer digs
into the details of the notice of proposed rulemaking. She
- The anticipated list of pre-approved activities eligible for
CRA credit and how it will be updated.
- How the proposal addresses concerns about CRA activities in
- The proposal’s new concept of assessment areas based on where
banks have a significant share of deposits and retail lending —
beyond their facility-based assessment areas.
- The proposal’s new approach to CRA evaluation, which includes a
set of performance standards against benchmarks and set in a bank’s
local performance context.
- Implications of the proposed changes for banks’ reporting and
data systems and the agencies’ discussions with core providers and
other vendors to support the changes.
- How the opt-out for banks with less than $500 million in assets
would work — and what new data smaller banks would still have to
collect even if they opt out.
Comments on the proposal will be due 60 days after it is
published in the Federal Register. ABA encourages all banks to
comment; ABA members can register for a free
webinar on Dec. 19 providing more details on the proposed
rule and tips for writing a comment letter.