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Financial Institutions Community Reinvestment Act Financial Regulatory Reform

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Have Regulators Already “Raised the Bar” for CRA Exams?

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When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it...more

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The new Community Reinvestment Act Omits Critical Types of Credit That Meet Community Needs

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Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule.  But perhaps their frustration should be focused on the regulators who have...more

Ballard Spahr LLP

Banking Regulators Ask Fifth Circuit to Lift Injunction Blocking CRA Rules

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Federal banking regulators are asking the Fifth Circuit Court of Appeals to lift a Texas court injunction barring implementation of new Community Reinvestment Act (CRA) rules....more

Ballard Spahr LLP

FDIC Chairman Gruenberg issues remarks at National Community Reinvestment Coalition on FDIC’s economic inclusion strategy

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FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy.  ...more

Sheppard Mullin Richter & Hampton LLP

Persisting Regulatory Uncertainty: Federal Regulators Delay New Community Lending Rules

On March 21, the FDIC, Fed, and OCC jointly issued an interim final rule to extend the applicability date of certain provisions of the Community Reinvestment Act (CRA) final rule and requested comments on the extension. The...more

GeoDataVision

Will the Regulators Implement a Key CRA Rule Component by Stealth?

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Now that a Texas court has issued a temporary injunction delaying the April 1, 2024, scheduled implementation of the new CRA Rule should bankers relax and assume that the new rule’s effective date has been delayed for at...more

Troutman Pepper

Texas Federal Court Grants Preliminary Injunction in Community Reinvestment Act Lawsuit

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On March 29, a Texas federal court granted a preliminary injunction enjoining the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the...more

Ballard Spahr LLP

TX federal court enjoins enforcement of CRA final rules against plaintiffs

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On February 5, 2024, several national and Texas banking and business trade groups (Plaintiffs) filed a lawsuit challenging the final regulations (Final Rules) implementing the Community Reinvestment Act of 1977 (CRA) that...more

GeoDataVision

Postponement of April 1, 2024 “Applicable” Date May Cause More Confusion

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The March 21, 2024, announcement that the prudential bank regulators have decided to postpone the scheduled April 1, “applicable” date for the Facility-based assessment areas, the new Public File section and the Public Notice...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - March 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

GeoDataVision

The Answers to the CRA Questions Everyone is asking: What must we do on April 1?

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With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers....more

GeoDataVision

New CRA Retail Lending Test Benchmarks

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The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many bankers, although not...more

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2024 Regulatory Hot Topics

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Episode 70 of "Compliance 911, show" titled "2024 Regulatory Hot Topics," discusses the major regulatory challenges facing financial institutions in 2024. Hosts Len and Dean mark their 70th episode, reflecting on various...more

Latham & Watkins LLP

Banking Trade Groups Challenge New Community Reinvestment Act Regulation

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Banking agencies are alleged to have exceeded their congressional authorization, with potentially adverse consequences on banks and consumers. On February 5, 2024, several banking trade groups[1] (the Plaintiffs) sued...more

Jones Day

OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

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The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more

GeoDataVision

The new CRA: Surprises and Problems by Omission

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I have written a number of articles about the new CRA and the problems its requirements will impose on banks. But there are also problems posed by what the new Rule omits....more

GeoDataVision

The new CRA Rule: Confusion Reigns

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Our office has been inundated with inquiries about an aspect of the impact of the impending new CRA rule. As we have noted in previous articles there are mistakes and inconsistencies in the new CRA Rule, and some of these...more

GeoDataVision

The New CRA Rule: Another Surprise – for Banks and maybe for the Regulators too (part of a series taking a critical look at the...

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The new CRA Rule has a number of surprises for banks and maybe a surprise or two for the regulators themselves. One of those surprises involves the transition rules in §__.51 as they pertain to the April 1, 2024, the...more

GeoDataVision

Part V5; A Critical Review of Serious Flaws in the New CRA

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Most of the articles published about the new CRA rule have repeated the party line – that the new rule “modernizes” the Regulation, that it will make CRA exams more objective and CRA ratings more consistent, etc. But the new...more

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The Disastrous New CRA Rule: Part IV – Is the 80% Retail Lending Assessment Area Exemption Really a Break for Large Banks?

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Dear Banker, The new CRA Rule contains a "break" for Large banks that would exempt them from having to declare Retail Lending Assessment Areas ("RLAAs") for any calendar year in which the bank lends more than 80% of its home...more

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The Disastrous New CRA: Part III – It’s worse than you think and which banks are hurt the most

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In Parts I and II I explained the devastating impact of the new CRA Rule and what the underlying reasons for that adverse impact are. In Part III I will touch upon what banks are most significantly impacted by the new Rule....more

Ballard Spahr LLP

The New CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 3

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This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

GeoDataVision

New CRA Rule is a Disaster for Banks: Part I – And the Numbers Prove it!

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With all the news stories circulating about the new CRA Rule, it's surprising that not one article has addressed the topic that should be the biggest story of all - the catastrophic implications for banks!...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 2

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This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks #1

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On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations...more

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