Modernizing the CRA: The Agencies’ New Proposed Rule – ON-DEMAND WEBINARS

Date Recorded: July 18-19, 2022
Presenters: Anetria Cohen, Vice President and Senior Consultant, ProBank Austin and Brian Waters, COO and Co-Founder, findCRA

The Community Reinvestment Act (CRA) encourages depository institutions to help meet the credit needs of the entire communities in which they operate, including low and moderate-income neighborhoods, and are required or encouraged to ensure they lend, invest, and service in ways to develop their communities (community development). Institutions have long struggled with the CRA and its implementing regulations and Q&As – issues such as whether institutions could get “CRA credit” for an activity, how to define assessment areas, and examination results always have been too subjective, leading to inconsistent results and frustration among institutions.

After an eventful couple of years in which the OCC finalized revisions by itself, and then rescinded those revisions a short time later, the banking agencies – the Comptroller of the Currency (OCC), the Federal Reserve, and the Federal Deposit Insurance Corporation – are now working together and issued a proposed rule that substantially revises how banks and savings associations will be examined for compliance with the CRA.

These two sessions will review in detail the proposal, as well as the effective date and compliance dates. For the first webinar, we will cover changes to qualifications, assessment areas, asset sizes, etc., that apply to all banks. For the second webinar, we will dive into the new examination process, more specifically focusing on the changes in examination and recordkeeping for Large Banks. In doing so, we will review the requirements applicable to large banks and small/intermediate banks, new aspects of the rule (e.g., Qualifying Activities, New Retail Lending and Community Development Financing Retail Lending), as well as revised rules (e.g., Assessment Areas, Data Collection).

Participants have the choice to sign up for both webinars or either one.

HERE’S WHAT YOU’LL LEARN:

Day One – Rules that apply to all banks:

• Asset size threshold revisions
• New criteria for CD activities, provision of a list
• Assessment areas, including the new retail lending assessment area for Large Banks
• Revised standards and options for Intermediate and Small Banks
• Compliance and transition dates

Day 2 – Focus on new examination rules:

• New standard for Large Banks (four performance tests)
• Updated data collection and reporting
• Examination process and results
• Compliance and transition dates