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MoFo Reenforcement The Enforcement Blog

Proposed Revisions to Community Reinvestment Act Q&A’s

Posted in Regulatory Developments

On September 10, 2014, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, “the Agencies”) requested comment on their  proposed revisions to interagency guidance on the Community Reinvestment Act (CRA), specifically to the Interagency Questions and Answers Regarding Community Reinvestment (Guidance). The proposed revisions are in response to questions and comments that bankers, community organizations, and others recently raised about the Agencies’ CRA regulations. The Agencies seek to revise three questions and answers in the existing guidance, addressing (1) alternative systems for delivering retail banking services and providing additional examples of innovative or flexible lending practices, and (2) community development-related issues, including clarification on what activities the Agencies consider as revitalizing or stabilizing for certain underserved communities. The Agencies are also proposing to add four new questions and answers addressing how the Agencies evaluate community development services, including the qualitative and quantitative factors considered, as well as general guidance on how the Agencies evaluated the responsiveness and innovativeness of a financial institution in responding to community development needs. Comments are due November 10, 2014. The full text of the request for comment provides additional details on the purpose behind, and the text of, the proposed revisions.