Alex Barrage, a partner with Troutman Pepper Locke, was quoted in the January 9, 2025 American Banker article, “CFPB Rules, M&A Standards Most Likely CRA Repeal Targets.”
Alexandra Barrage, a partner at Troutman Pepper Locke, said the CRA will likely not be a primary tool for regulatory rollbacks because many of the same rules that the incoming administration is most opposed to are already being fought in court.
“The CRA is important to all, but it’s certainly not the only tool that the industry is using on some of these rulemakings,” she said. “In this world, the litigation that we’ve already seen across multiple rules is really where so much of the action currently is.”
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Barrage notes that the OCC’s bank merger application standards — unlike the FDIC’s, which are technically a statement of policy — constitute a final rule, and thus could be subject to the CRA.
“I think that’s the only [major prudential] rule that would be CRA-able,” she said. “Whereas guidance can be pulled back by the agency [under the next administration].”
