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Warren W. Traiger extensively quoted in Dodd Frank Update article, “CRA reform could take many shapes”

Dodd Frank Update

Warren W. Traiger

Warren W. Traiger was extensively quoted on January 28, 2020 in a Dodd Frank Update article, “CRA reform could take many shapes,” which discussed the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corp. (FDIC) decision to join together in publishing a notice of proposed rulemaking (NPR), and the missing endorsement for the proposal from the Federal Reserve. The article stated, “Industry insiders have been in sync in their conviction that CRA reform is best done with the three banking agencies acting in tandem. Many agree that to do so otherwise likely would lead to headaches down the road.”

In noting the differing ideas between the OCC and the Fed, Traiger said, “The OCC is much more committed to having the same metrics apply to every kind of bank, where the Fed maintains that there should be a distinction between retail banks, wholesale banks and limited-purpose institutions. The Fed would have individual metrics that are very much tailored to each size of business strategy of banks subject to CRA requirements, whereas the OCC would apply the same set of metrics to all banks with more than $500 million in assets.

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