All in CRA

OCC Solicits Comments on Modernizing CRA Regulations

Adam Witmer
Regulatory Update, CRA

On August 28, 2018, the Office of the Comptroller of the Currency (OCC) issued an advance notice of proposed rulemaking (ANPR) inviting public comment on ways to modernize the regulations that implement the Community Reinvestment Act (CRA).  In their notice (OCC-2018-0008), the OCC is soliciting ideas on how the CRA rules could better achieve the statute’s original purpose, encourage increased lending and investment where it is needed the most, and reduce the burden associated with reporting and evaluating CRA performance. As the OCC plans to share the results of the ANPR with other regulatory agencies, all financial institutions are encouraged to provide comments to the OCC.

Compliance Considerations for CD Secured Loans

Adam Witmer
Compliance Management, BSA, Fair Lending, CRA, Regulation Z

Compliance requirements for CD secured loans are not typically a huge topic of discussion for compliance seminar speakers or article authors.  That said, one of our members suggested this topic (you know who you are!), and I think it is a great topic to write on from the perspective of CD secured loans, rather than just bringing up these loans when discussing applicable regulations (which is usually the way it happens). The truth is that most financial institutions (and regulators) just…

Agencies Release July 2018 List of Banks Examined for CRA Compliance

Adam Witmer
CRA, Regulatory Update

Each month, the FDIC and OCC each release a list of banks that have been evaluated under the Community Reinvestment Act (CRA).  This information is extremely valuable to CRA officers as one of the best ways to understand the CRA requirements for a financial institution is to read the performance evaluations of other financial institutions of the same regulator. This article summarizes some of the key points from these evaluations.

Agencies Release CRA Ratings for June 2018

Adam Witmer
CRA, Regulatory Update

Last week, the OCC and FDIC released their monthly list of CRA ratings from June of 2018.  The following summary provides a few noteworthy highlights from this months ratings. As we have advocated before, one of the best ways for a financial institution to understand their requirements under the Community Reinvestment Act (CRA) is to read the performance evaluations from other financial institutions.

OCC Issues Guidance on CRA Performance Evaluation Process

Adam Witmer
Regulatory Update, CRA

On June 15, 2018, the OCC issued a bulletin (2018-17) on supervisory policy and processes for Community Reinvestment Act (CRA) performance evaluations.  This bulletin was issued to inform national banks, federal savings associations, and federal branches and agencies (collectively, banks) regulated by the OCC about clarification to the OCC’s supervisory policies and processes regarding how examiners will now evaluate and communicate bank performance under the CRA.  This new guidance is effective immediately, though financial institutions that are currently in the middle of a CRA examination may see the use of transitional procedures.

FDIC & OCC Release List of CRA Performance Evaluations for May 2018

Adam Witmer
CRA

As is the case each month, the OCC and FDIC released a list of Community Reinvestment Act (CRA) performance evaluations from May of 2018.  These evaluations are a fantastic tool for compliance professionals to understand the CRA requirements, what examiners expect, and best practices for improving CRA ratings.  Specifically, a great deal of information can be learned by reviewing both the Outstanding and Substantial Noncompliance performance evaluations. Therefore, we are again providing an overview of noteworthy trends from these recent performance evaluations. The following is a summary of highlights from these performance revi…

CRA Evaluation Examples from the FDIC & OCC

Adam Witmer
CRA, Regulatory Update

Both the FDIC and the OCC recently released their list of financial institutions that were evaluated for the Community Reinvestment Act (CRA), as well as the corresponding CRA ratings.  By law, the agencies are required to regularly publish this data and it is always insightful as to what examiners might be looking for when it comes to CRA.  In fact, I strongly believe that one of the best ways to understand CRA is to read the performance evaluations of other financial institutions, specifically those that are...

2018 CRA Threshold Update

Adam Witmer
CRA, Regulatory Update

Each year, the asset-size threshold under the Community Reinvestment Act (CRA) is updated based on inflation.  This threshold is important as it determines which CRA test a financial institution will have during their CRA exam.  For 2018, the following thresholds will apply: