US Office Of The Comptroller Of The Currency Publishes Advanced Notice Of Proposed Rulemaking With Respect To Community Reinvestment Act Modernization

Author:Shearman & Sterling LLP
Profession:Shearman & Sterling LLP
 
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On August 28, 2018, the U.S. Office of the Comptroller of the Currency issued an advanced notice of proposed rulemaking with respect to the modernization of the Community Reinvestment Act. The notice highlights that a revised CRA framework will allow financial institutions to more effectively serve the needs of the communities in which they operate by focusing CRA activities to where they are needed most, providing greater clarity with respect to CRA-qualifying activities and evaluating CRA activities more consistently. With respect to the latter, the notice provides that a modernized CRA framework will allow for more timely evaluation of the CRA activities of financial institutions, result in greater transparency and consistent interpretation of the CRA and reduce the regulatory burden of financial institutions. The specific requests for comment are organized into two subcategoriesevaluation of the existing CRA framework and the modernized CRA framework. With respect to the existing CRA framework, the notice requests comments regarding whether the current framework is easy to understand, consistently applied and transparent; whether the current framework supports the goals of the CRA; and which aspects of the current framework are successful or should be retained. With respect to the...

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