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Banking and Financial Services Update

Federal Reserve Board Announces Proposal for Modernizing Community Reinvestment Act Regulations

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The U.S. Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC, and together with the OCC and the Board, the Agencies) share oversight responsibility for the implementation of the Community Reinvestment Act (CRA) with respect to the depository institutions under their respective supervision. Prior to this year, the Agencies issued joint rulemakings to align on consistent regulations implementing the CRA. In a departure from this tradition, the OCC issued a final rule on May 20, 2020 (the OCC Final Rule) fundamentally revising the CRA regulations for OCC-regulated institutions. On September 21, 2020, the Board issued its own Advance Notice of Proposed Rulemaking (ANPR) to solicit comments on a significantly different approach also to substantially overhaul the Board’s version of the CRA regulations. While the FDIC participated in the OCC’s notice of proposed rulemaking in December 2019, it has not joined either the OCC’s Final Rule or the Board’s ANPR, leaving the industry with uncertainty and the potential for three versions of CRA regulations.

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