CBAI responded to the Office of the Comptroller of the Currency’s (OCC) Advance Notice of Proposed Rulemaking (ANPR) on reforming the Community Reinvestment Act (CRA or Act) regulatory framework. The CRA was enacted by Congress in 1977 to encourage insured depository institutions to help meet the credit needs of their communities, including low- and moderate-income (LMI) neighborhoods, consistent with the safe and sound operation, but has been little changed since then. This modernization effort is a historic opportunity to highlight and retain parts of the Act, identify missed opportunities for additional credit, reduce the regulatory burden on community banks and include many other financial service providers for compliance. CBAI included in its comprehensive comment letter numerous observations and recommendations for improvement related to:
- increasing lending and services to people and in areas that need it most, including in LMI areas;
- clarifying and expanding the types of activities eligible for CRA consideration;
- revisiting how assessment areas are defined and used;
- establishing metric-based thresholds for CRA ratings;
- making bank CRA performance more transparent;
- improving the timeliness of regulatory decisions related to CRA; and
- reducing the cost and burden related to evaluating performance under the CRA.