What Commenters Have to Say About Proposed CRA Updates

Finally, almost a decade after announcing a joint effort to modernize the Community Reinvestment Act, the prudential regulators have signaled that revisions are in the offing. Over the last two months, representatives from the Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation and Federal Reserve have each indicated their willingness to work together to revise the rules that implement the CRA.

Renewed deliberations began last autumn, when the OCC published an advanced notice of proposed rulemaking, or ANPR, that solicited answers to 31 questions about the CRA. In response, national- and state-chartered banks, trade associations, community advocates, representatives of federal, state and local government, and others submitted approximately 1,500 comments. The regulators are reportedly meeting this month to begin formulating a proposed rule, and the OCC and FDIC have suggested that a modernization process that includes the Fed could be completed within a year.

Originally published in Law360; reprinted with permission.