There are some signs that regulators are becoming aware of the major problems inherent in the 2022 CRA NPR and are starting to question the cost and benefits of the proposed Rule.
In an August 6, speech before the Kansas Bankers Association, FRB Governor Michelle Bowman said, “While I am a strong supporter of the fundamentals behind CRA, and I support community development activities, I am concerned that the proposal does not adequately account for the costs and benefits of certain provisions, and that no attempt has even been made to either ensure that or to analyze whether the benefits exceed the costs, which is a fundamental element of effective regulation“.
I would encourage bankers to contact the members of the Financial Services Committee to express concerns. Keep in mind that the flaws in the NPR hurt not only banks, but the communities they serve by shifting focus away from local communities where bankers work and live to potentially markets far removed from any of their branches.
The Comment period may have passed, but that doesn’t mean bankers can’t contact their congresspeople and let them know about all the flaws in the CRA NPR.
Attached is Governor Bowman’s speech. Her comments about CRA are about 80% into the speech.
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