It has been years since the federal bank regulatory agencies have overhauled the Community Reinvestment Act (CRA) regulations. Right now, major revisions are unfolding, but in awkward manner. This program provides a review of the existing CRA rules, the FDIC’s proposed rule, the OCC’s final rule, and an explanation of the Federal Reserve Board’s Advanced Notice of Proposed Rulemaking.
Covered Topics
This program provides a review of the current, the FDIC’s proposed, the FRB’s advanced proposed, and the OCC final requirements of CRA and its implementing regulations, including:
- Existing, proposed and revised performance tests, standards, and ratings;
- Assigned ratings under current, proposed and revised regulations;
- Assessment area delineation under the current rule and the new facility-based and deposit-based methods;
- New concepts such as retail deposits, retail lending product lines, and qualifying activities lists;
- Evaluation concepts such as CRA Evaluation Measures, geographic distribution tests, and borrower distribution tests;
- Evaluation options under current, proposed and final rules;
- Current data collection requirements and the expanded requirements under the proposed and final rules;
- Community Development activities under the current, proposed and revised regulations;
- The status of “intermediate small banks.” (Will the category continue to exist?);
- How small is a “small bank” under existing ($1.305 billion), proposed ($500 million) and revised regulations ($600 million);
- An explanation of the periodic adjustments to the asset-size thresholds used to define “small bank” and “intermediate small bank;”
- A review of recent redlining cases;
- A review of the CRA Questions and Answers, exam results and CRA agreements; • Public file requirements;
- CRA notices;
An explanation of how to obtain community development credit for COVID-19-related activities; and - The status of the proposed and final revisions to the regulations.
Who Should Attend?
The program is designed for loan officers, compliance officers, CRA officers, loan department staff, bank counsel and auditors. Whether new to the requirements of the CRA and its regulations or a seasoned veteran, this program provides a comprehensive review of the rapidly changing requirements of the CRA.