In a recent comment letter, WBA wrote the Office of the Comptroller of the Currency (OCC) to comment on its Advanced Notice of Proposed Rulemaking (ANPR) on reforming the Community Reinvestment Act regulatory framework. 

The Community Reinvestment Act of 1977 (CRA) was enacted to encourage financial institutions to help meet the credit needs of the communities that they serve. Federal regulators assess the record of a bank in meeting the credit needs of its entire community, pursuant to regulation. OCC issued the ANPR to solicit ideas for building a new framework to transform or modernize its regulations.

WBA requested revisions to the CRA framework that would provide clarity regarding activities that receive positive CRA consideration, thresholds for identification of community development loans, counting credit for the lending test, reporting requirements, and the assessment area concept. These comments were provided, with examples, pursuant to input from our members.

In addition to requests for specific revisions, WBA urged OCC to work with FDIC and FRB in developing a consistent proposed rule.