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OCC Issues Bulletin on CRA Ratings Impact on Licensing Applications
On Wednesday, November 8, 2017, the OCC issued a bulletin on guidance to provide transparency regarding its framework for evaluating certain types of licensing applications when an applicant bank has an overall Community Reinvestment Act (CRA) rating of “Needs to Improve” or “Substantial Noncompliance” (together, less than satisfactory CRA performance rating) or a less than satisfactory CRA rating in one or more geographic rating areas. This guidance applies to all national banks, federal savings associations, and federal branches of foreign banks subject to the CRA. It also applies to state-chartered institutions subject to the CRA that propose to convert to a federal charter.