Back to the Old Way? How to Best Meet Expectations in a Changing World
After what has seemed like an endless series of irregular periods of action, the banking regulators finally issued their long-awaited amendments to the Community Reinvestment Act (CRA) regulations, only to have them rescinded. The previous CRA regulations (meaning the ones in place that banks comply with now) will remain until further notice. Is this a good thing? Depends on who you ask.
Banking has come a long way since 1977, when the original CRA regulations were issued – we’ve seen the evolution into digital products and services, the incredible new array of products and services, and major changes in the way those products are delivered, and arguably the CRA regulations haven’t kept pace, making it harder to achieve a satisfactory (or better) rating.
But the core concepts of the CRA remain: banks are evaluated on their performance within their communities, particularly on the lending side, with a particular focus on Low- and Moderate-Income (LMI) areas within its assessment area.
What You’ll Learn
- Current state of CRA: dealing with the current requirements
- The unique nature of the CRA regulation – different from all others
- Why did the new rule go away? Will it come back?
- Valuable information we can utilize from the now-rescinded amended regulation – not all is lost
- Definition of “assessment area” – what this means and concerns and risks to take into account
- Differing standards for different banks based on asset size – thresholds and specific requirements
- Small Business and Small Farm loans – how to tell
- Data collection and reporting requirements for large banks
- Public file – contents and disclosure
- Lending evaluation for all banks, but especially small banks
- Investment and Service tests for larger institutions
- Evaluation of activities in “non-branch delivery systems, such as online and mobile banking, branchless banking, and hybrid models.” What does this mean? What will be evaluated?
- Framework to evaluate digital delivery of products and services
- Listing CRA-eligible activities – what are these?
- Clarity with “community development”
- Asset-size thresholds – what are the responsibilities within each of these tiers?
- Transparency with the public, including encouraging public input on community needs and opportunities
- Reinforcing the connection between CRA and fair lending – it’s always been there
- Strategic plan option
Who Should Attend
This webinar will be useful for anyone in the bank who has any sort of direct responsibility under the CRA, including compliance professionals, risk managers, auditors, legal counsel, and others. As well, anyone on the lending side of the bank who will be responsible for any of the many activities, products, services, and activities that are evaluated, will benefit from the discussion. Senior management and Boards members will benefit by understanding what the new requirements entail and the timeframes for compliance with the new standards.