Community Reinvestment Act Modernization – For Real This Time?

59 minute watch | June.28.2022

The OCC, FDIC, and Fed recently issued a proposed rule and request for comment as part of their continued efforts to modernize the Community Reinvestment Act, last overhauled in 1995. This proposal is a welcome demonstration of agency unity, but does it hit the right notes for a practical modern framework? The agencies pose 180 questions in the proposal, suggesting there is room for fine tuning. Unless extended, the comment submission deadline is August 5.

Orrick attorneys Warren Traiger and Lauren Bomberger, who are assisting financial services trade associations and individual banks with analyzing and commenting on the modernization proposal, discussed the substance of the rule, including how it differs from current law, which banks are affected, and key opportunities for comment.

Webinar filmed prior to the combination of Buckley and Orrick in 2023.

The information contained herein is for informational purposes only, does not constitute legal advice, and does not necessarily reflect the opinions of Orrick or any of its attorneys or clients. This presentation is not intended to create, and does not create, an attorney-client relationship between you and Orrick, or any of the presenters, and you should not act or rely on any information in this presentation without consulting legal counsel. The information contained in this presentation may or may not reflect the most current legal developments. Accordingly, information in this presentation is not promised or guaranteed to be correct or complete, and it should not be considered an indication of future results. Orrick expressly disclaims all liability in respect to actions taken or not taken based on any or all of the contents of this presentation.

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Warren Traiger Senior Counsel, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

New York

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Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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Warren Traiger Senior Counsel

New York

He argued before the U.S. Court of Appeals for the Second Circuit in Lee v. Board of Governors, a benchmark case regarding the rights of community organizations to challenge Federal Reserve Board (FRB) determinations on merger applications. He has testified before Congress and the federal banking agencies on fair lending and CRA reform, served as Special Counsel to the New York banking regulator on CRA, and advised the regulator on predatory lending regulation.

Warren regularly helps banks and bank holding companies prepare the community convenience and needs portion of their regulatory applications to merge or acquire, and he helps clients respond to public comment regarding CRA and fair lending compliance. He represented a bank in its acquisition and integration of the finance arm of major automaker, directing pre-acquisition fair lending due diligence and updating the combined entity’s policies, procedures and regulatory relations strategy. Warren also served as an independent consultant for the New York Attorney General, overseeing compliance with that office’s settlement with a company that provides criminal background checks on prospective employees.

A prolific writer and researcher, Warren’s research and statistical analysis of mortgage lending data has been cited in publications of the Federal Reserve Banks of San Francisco, Boston and Dallas; the Federal Deposit Insurance Corporation (FDIC); and in testimony before the U.S. House Financial Services Committee.

Prior to joining Orrick, Warren was senior counsel at Buckley LLP. He also served as Co-Chairman of Traiger & Hinckley LLP. Prior to entering private practice in 1990, Warren was vice president, counsel and director of government relations for the New York Bankers Association, the trade group for New York commercial banks. He also served as director of legislation and research and special counsel for the New York City Department of Consumer Affairs and as a New York State Consumer Protection Board official.

Warren is entrenched in the New York legal and financial services community. He has served on the Banking Law Committee of the New York State Bar Association, as a member of the Banking Law and Consumer Law Committees of the Association of the Bar of the City of New York, and has taught as adjunct professor of economics at Hunter College of the City University of New York.