News

Extremely Important Announcement regarding PPP loans: Free SBA book containing the size standards

Many bankers have not collected the GAR information for the PPP loans they have extended to businesses. While this has not been required by regulators it could jeopardize the recognition of many loans that would qualify for community development credit under CRA examination standards because to qualify for "economic development" a loan must pass both the "purpose test" (job preservation) and a "size test" (the borrower must have GAR <=$ million or must meet the SBA size standards in Part 121 of the SBA Regulations).

New Community Reinvestment Act (CRA) Rule has big and different impact on OCC regulated institutions depending on asset size

The new Community Reinvestment Act (CRA) rule approved by the OCC on May 20, will have a very big impact on more than just the newly defined "large banks" (defined as having assets >$2.5 billion) who will be subject to the radically new performance tests (the "CRA Evaluation Test", the "Distribution Tests" and the "Community Development Minimum Test").

Some OCC-regulated lenders will get a very big benefit and some will get a very bad surprise depending on their asset size.

New Community Reinvestment Act (CRA) Rule will leave 90% of OCC-regulated institutions without important Performance Context information

If you are an OCC-regulated institution and are not classified as a large bank under the new Community Reinvestment Act (CRA) regulations you may be breathing a sigh of relief. But don't be too relieved because the provisions in the new rule have very important and very bad implications for you too.

Are your CRA performance standards unfair or unclear? Maybe it's because you inflated your own CRA requirements

Dear Banker,

I can't tell you how often I've heard bankers complain about "unfair" or "unclear" performance expectations. They don't seem to understand they set CRA performance standards when they delineate their Assessment Areas.  

The biggest CRA-related decision you will ever make is how you delineate your Assessment Area.

Why? Because how you define your market determines not only your results; it also is what defines your "performance context" - and it is performance context that drives performance standards.

Webinar regarding the proposed CRA changes

Dear banker,

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.