On April 8, 2020 WBA filed comments on the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation’s (agencies) proposed revisions to the Community Reinvestment Act (CRA) regulations (proposed rule). The agencies proposed to clarify which activities qualify for CRA credit, update where activities count for CRA credit, create a new method for measuring CRA performance, and new CRA-related data collection, recordkeeping, and reporting requirements.
WBA commented that while banks remain committed to the CRA goals, the regulation has become overly complex, unpredictable, and not kept pace with modern trends and technology. In the letter, WBA requested additional clarity on various aspects of the methods mentioned above, recommended changes, and highlighted the need for significant reduction in burden by providing examples of costs. Lastly, WBA urged all three banking agencies—the OCC, FDIC, and Federal Reserve—to develop a final CRA rule that is issued on an interagency basis.