The Community Reinvestment Act (CRA) for OCC Institutions: Transitioning Back to the Old CRA Rules – ON-DEMAND WEBINARS

Recorded: April 14, 2022
Presented by: Ms. Anetria Cohen, Vice President and Senior Consultant, ProBank Austin and Brian Waters, President and Co-Founder, findCRA

A ninety-minute webinar that focuses on transition issues caused by rescission of the OCC’s CRA 2020 rules.

In an effort to modernize and address criticisms of the Community Reinvestment Act (CRA) regulatory framework, the Comptroller of the Currency (OCC) adopted substantial revisions to its CRA regulations, effective October 2020 (with varying compliance dates) (October 2020 rule). The Federal Reserve and Federal Deposit Insurance Corporation (FDIC) did not join the OCC in this rulemaking. In December 2021, the OCC announced that it was rescinding these revisions, and reverting to the regulations that existed prior to the October 2020 rules, citing the importance of the OCC, the Federal Reserve, and the FDIC to issue a single set of rules applicable to all banks and savings associations. The rescission and reversion were generally effective January 1, 2022.

Given the changing rules, OCC-regulated institutions have many questions and concerns regarding how to handle this transition as some institutions converted, or were in the process of converting their policies, procedures, and training,

This webinar will review and clarify how OCC-institutions should approach to these transition issues, which rules to comply with, and when to comply, addressing issues such as which activities qualify for credit, the decrease in the asset-size thresholds, data collection and recordkeeping activities, and notice requirements.

HERE’S WHAT YOU WILL LEARN:

The following transition issues:

• Qualifying activities
• Confirmation process
• Illustrative list
• Bank asset-size thresholds
• Data collection, recordkeeping, and reporting
• Affiliate activities
• CRA activities outside of a bank’s assessment area
• Public file/notice