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Community Reinvestment Act: Modernization Proposal Comment Extension

3/27/2020 - By Connie Edwards, CRCM

While you are quarantined at home getting your social distancing on, if you’re a CRA professional for your financial institution, you need to set aside some time to read and review the CRA modernization proposal issued by the OCC and FDIC from December 12th, 2019.

As most of the industry, I typically don’t spend much time reviewing “proposed” regulations because they can change so drastically by the release of the final rules. However, this Proposal is far too important for you not to take the time to comment. Embedded within this Proposal is approximately 19 questions that the FDIC and OCC need to hear from you regarding how this Proposal will impact your institution and specifically, your community.

The jury is still out on what will happen in regards to the Federal Reserve. Will they sit down with the OCC and FDIC and try to work through their issues with the Proposal or will they issue their own CRA modernization proposal?

There is no clear reason as to why we were granted an additional 30-day extension comment period, though I am very thankful for it. It will end on April 8th, 2020, so it will provide some additional time for you to comment on this important topic. Take advantage of this time that you are possibly sequestered at home to read and comment!

Commenters are encouraged to submit comments through the Federal eRulemaking Portal or email, if possible. Please use the title “Community Reinvestment Act Regulations” to facilitate the organization and distribution of the comments. 

You may submit comments to the OCC by any of the following methods:

  • Federal eRulemaking Portal
    • ­Enter “Docket ID OCC-2018-0008" in the search box
    • ­Click on “comment now” to submit public comments
    • View Commenter’s Checklist for help with submitting effective comments
  • Email: cra.reg@occ.treas.gov
  • Mail: Chief Counsel’s Office
            Attention:  Comment Processing
            Office of the Comptroller of the Currency
            400 7th Street, SW., Suite 3E-218
            Washington, DC  20219
  • Fax: (571) 465-4326

You may submit comments to the FDIC by any of the following methods:

  • Agency Website
    • Follow instructions for submitting comments on the Agency’s website
  • E-mail: Comments@fdic.gov
    • Include the RIN 3064-AF22 on the subject line of the message
  • Mail: Robert E. Feldman, Executive Secretary,
            Attention:  Comments
            Federal Deposit Insurance Corporation
            550 17th Street NW
            Washington, DC  20429

Please take the time to comment - it will be vitally important to the future of your institution’s CRA program. As I tell my Compliance Forum members all the time, if you don’t comment, you get what you get, so don’t throw a fit.

Additional Resources & Information

About the Author | Connie Edwards, CRCM
Connie is a shareholder in the Financial Institution Advisory Group of Saltmarsh, Cleaveland & Gund. Her areas of expertise include development and implementation of risk-based compliance audit programs, in addition to a wide range of legal and regulatory affairs knowledge in both private and corporate practice environments. She previously served as President and CEO of her own compliance consulting practice Banc Compliance Group, LLC, where she worked extensively with institutions regulated by the Federal Reserve’s Atlanta and St. Louis District offices; the Office of the Comptroller of the Currency; and the Federal Deposit Insurance Corporation.

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