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Financial Services Law Insights and Observations

OCC issues CRA compliance resources

Agency Rule-Making & Guidance OCC CRA Compliance

Agency Rule-Making & Guidance

On October 1, the OCC released three items in support of the implementation of the new Community Reinvestment Act (CRA) final rule. The three newly released items include: (i) a compliance guide for small banks; (ii) an initial illustrative list of qualifying activities; and (iii) a form to request consideration of items to be added to the list of qualifying activities. As previously covered by a Buckley Special Alert, the OCC’s rule, while technically effective October 1, provides for at least a 27-month transition period for compliance based on a bank’s size and business model. Large banks and wholesale and limited purpose banks will have until January 1, 2023 to comply, and small and intermediate banks that opt-in to the final rule’s performance standards will have until January 1, 2024.

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