CRA Review and Update

Monday, September 11, 2023 9:00 AM - 4:00 PM   iCalendar Central Standard Time

It has been years since the federal bank regulatory agencies overhauled the Community Reinvestment Act (CRA) regulations. Right now, major revisions are unfolding, but in an awkward manner. This program provides a review of the existing CRA rules and the proposed rule waiting for finalization. Participants receive a detailed manual that serves as a handbook.

  • On December 12, 2019, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released a Notice of Proposed Rulemaking (NPR) intended to increase bank activity in low- and moderate-income communities where there is significant need for credit, more responsible lending, greater access to banking services, and improvements to critical infrastructure.
  • On May 20, 2020, the OCC approved a final rule to modernize the CRA regulations. The final rule is effective on October 1, 2020, but it will be several years before national banks have to fully implement the regulations.
  • On September 21, 2020 the Federal Reserve Board (FRB) released an Advanced Notice of Proposed Rulemaking that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks.
  • On May 18, 2021, the Office of the OCC published OCC Bulletin 2021-2, which states that the OCC has determined that it will reconsider the final CRA Rule published on June 5, 2020. This is a major step towards achieving uniform revised CRA regulations.
  • On July 20, 2021, the FRB, the FDIC, and the OCC jointly announced the agencies are committed to working together to strengthen and modernize regulations implementing the CRA. The OCC separately announced it will propose rescinding the CRA final rule issued in May 2020 and is committed to working with the FRB and the FDIC to put forward a joint rulemaking that strengthens and modernizes the CRA.
  • December 14, 2021, the OCC issued a final rule to rescind the June 2020 Community Reinvestment Act (CRA) rule and replace it with a rule based on the rules adopted jointly by the federal banking agencies in 1995.
  • On May 5, 2022, The Board, along with the FDIC and the OCC, issued an NPR. The deadline for submitting comments on the NPR was August 5, 2022.

This program provides a review of:

  • 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) and proposed regulations ($600 million).
  • A review of recent redlining cases;
  • A review of the CRA Questions and Answers, exam results and CRA agreements;
  • Public file requirements;
  • CRA notices; and
  • The status of the proposed and final revisions to the regulations.

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.

Kimberly Boatwright is EVP and Director of Risk and Compliance at Compliance Resource, LLC, and has more than two decades of experience working in the financial services industry. Ms. Boatwright is a well-regarded financial industry risk and compliance professional with a strong background in program development and implementation. She is a thought leader who specializes in Fair Lending, Anti-Money Laundering, OFAC, and consumer compliance. During her career, she has worked for and consulted with all types of financial institutions, helping to establish and evolve compliance and risk programs. She is a frequent public speaker, trainer, and author on compliance and risk management topics. Kimberly is a Certified Regulatory Compliance Manager and a Certified Anti-Money Laundering Specialist.

Per Person Fee
(Includes OnDemand Access for 60 days for registered attendees)
IBA Member    $265
Nonmember    $445