CBA on OCC’s Community Reinvestment Act ANPR

August 28, 2018

CBA on OCC’s Community Reinvestment Act ANPR

Says ANPR is positive first step in modernizing CRA, ensuring community investment dollars put to work where most needed


WASHINGTON – The Consumer Bankers Association today said the advanced notice of proposed rulemaking issued by the Office of the Comptroller of the Currency was a positive first step in modernizing the Community Reinvestment Act and reaffirmed banks’ obligation to help meet the credit needs of their communities subject to safe and sound banking practices.


“The Community Reinvestment Act is a 40-year-old law last substantially updated more than two decades ago,” said CBA President and CEO Richard Hunt. “Banks have a continuing responsibility to meet the credit needs of their communities, but in recent years banking has seen major changes. Recognizing those changes and bringing CRA into the 21st Century will ensure community investment dollars are put to work where they are most needed.


“Comptroller of the Currency Otting should be commended for his dedication to updating this important law and we are encouraged by comments from other regulators on the need to modernize CRA. CBA and CBA members look forward to working with all involved groups as this process continues.”


While the OCC issued the ANPR alone, regulators at the Federal Reserve and Federal Deposit Insurance Corporation have spoken favorably about the need for CRA reform. A report issued earlier this year by the Department of the Treasury outlined recommendations in line with many of CBA’s recommendations.


CBA has outlined the following guidelines necessary for successful CRA modernization:

  • CRA should take into account the changing needs of communities, customer preferences and the digital transformation of banking;
  • Greater clarity and certainty is needed so banks can assess their performance and determine what will qualify as CRA eligible;
  • CRA should take into account banks’ business strategies and allow for those strategies through regulatory options; and,
  • CBA has also sought more timely performance evaluations in order to enhance the value of CRA for both the banks and the communities they serve.


NOTE: CBA Executive Vice President and General Counsel Steve Zeisel wrote an op-ed discussing the need to take into account digital banking. That op-ed is available here





About the Consumer Bankers Association

The Consumer Bankers Association represents America’s leading retail banks. We promote policies to create a stronger industry and economy. Established in 1919, CBA’s corporate member institutions account for 1.7 million jobs in America, extend roughly $4 trillion in consumer loans, and provide $275 billion in small business loans annually. Follow us on Twitter @consumerbankers.