Webinar regarding the proposed CRA changes
The FDIC and the OCC have published a Notice of Proposed Rule-Making for the Community Reinvestment Act ("CRA"). The NPR contains radical changes that dramatically affect the CRA responsibilities of every bank. You need to know what the proposed changes are and you should contact the FDIC and/or the OCC about them before it is too late!
The proposed changes are dramatic and will affect all banks in big ways.
Some of the changes include:
- "Deposit-based" Assessment Areas will be mandatory in addition to "facility-based" assessment areas when domestic deposits (as adjusted) outside assessment areas exceed 50%
- A new requirement to capture and report the location of your domestic deposits
- A new requirement that will include consumer loans be included in CRA data collected and reported
- The elimination of residential mortgages based on HMDA reported activity and the replacement of that data with mortgage activity based on the Call Report
- The elimination of the "Intermediate-Small" category of bank
- Large banks will now be defined as those with more than $500 million of assets
- Small business loans and small farm loans will now be defined as those of $2 million or less and will be adjusted for inflation going forward
This is only a partial list of the proposed changes
You have until April 8, 2020 to express your objections or approval of the proposed changes. You can be sure community activist groups will be expressing their opinions. This is your opportunity as a banker to get the ear of regulators and influence their final decision. Don't leave the final word to others!