On August 28, 2018, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) concerning modernization of the Community Reinvestment Act (CRA). CRA modernization can become a reality, but achieving it requires the involvement of as many financial institutions as possible. The first step is to comment on the ANPR. The ANPR can be reviewed here. 

The American Bankers Association has distributed a “Comment Letter Writing Guide”, which can be viewed here, that CBA recommends you use to compose your comments. As noted in the guide, you can pick and choose the issues you want to focus on, but you should send a response, even if you only address a few of the issues. Please be sure to include specific descriptions of the challenges your institution has faced in complying with CRA and in the CRA examination process.

Even though the ANPR was published by the OCC, both the Federal Reserve and the FDIC will be reviewing and evaluating comments in response to the ANPR, with the goal of creating a joint proposal by all three agencies for CRA modernization. Therefore, it is vitally important that all banks, regardless of regulator, respond, however briefly, to the ANPR to demonstrate to the OCC, the Fed, and the FDIC that the industry stands firmly behind CRA modernization. Community groups are very organized on CRA issues and have already filed numerous comment letters with the OCC.

THE DEADLINE TO SUBMIT COMMENTS IS NOVEMBER 19, 2018. DIRECTIONS ON HOW TO SUBMIT COMMENTS ARE INCLUDED IN THE ABA’S COMMENT LETTER WRITING GUIDE.