On Dec. 12, 2019, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency issued a 240-page proposal to amend the Community Reinvestment Act (CRA). The last major revision was almost 25 years ago. The intent is to modernize the rules and address criticisms that, in its current form, it lacks objectivity, transparency and fairness. The proposal clarifies which activities qualify for CRA credit, updates where activities count for CRA credit, creates a more objective method for measuring CRA performance and provides for more transparent, consistent and timely CRA-related data collection, recordkeeping and reporting. Due to the potential costs of compliance, the proposal allows banks with assets of $500 million or less to opt-in to the new rules or continue to be evaluated under the current CRA performance standards.


John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.