“The modernization of CRA’s outdated rules is long overdue, and we are very grateful to Comptroller Otting and the OCC staff for their commitment to this important effort. Stakeholders on all sides have acknowledged that the current CRA regime has failed to keep pace with the evolution of banking and community needs. We appreciate that today’s final rule identifies a list of activities that qualify for CRA credit that will be effective immediately. Banks and the communities they serve will benefit from this certainty. Additionally, the final rule recognizes the banking industry’s diversity by retaining the existing treatment for wholesale and limited purpose banks and by giving community banks with assets of up to $2.5 billion the choice to opt in to the new performance standards.
“We remain concerned about key provisions of the final rule including the substance and complexity of the performance measurement benchmarks, which will present significant data collection challenges for banks. The OCC’s decision to collect additional information and perform further analysis prior to setting the performance measurement benchmarks is a positive step at addressing those concerns, but our members still have many questions.
“We have consistently advocated for CRA modernization that encourages banks to invest efficiently and effectively in every neighborhood they serve. As the only banking trade association that represents banks of all sizes and charters, we have also advocated for clear and consistent rules for all banks. The fact that only one of the three federal banking regulators overseeing CRA has adopted this final rule means it does not meet that goal. We urge regulators to work in concert with all stakeholders to complete CRA modernization and reconcile the different regulatory regimes now in place to avoid any unintended consequences they could have on banks and the communities they serve.”