ARTICLE
26 June 2018

US Office Of The Comptroller Of The Currency Issues Clarifications Regarding CRA Evaluation

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A&O Shearman

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On June 15, 2018, the U.S. Office of the Comptroller of the Currency issued clarifying guidance with respect to the examination and evaluation of institutions under the Community Reinvestment Act.
United States Finance and Banking

On June 15, 2018, the U.S. Office of the Comptroller of the Currency issued clarifying guidance with respect to the examination and evaluation of institutions under the Community Reinvestment Act. The bulletin issued by the OCC notes that clarifications with respect to CRA evaluation processes were previously communicated to examiners, and that effective June 1, 2018, the OCC rescinded its previous "Large Bank CRA Examiner Guidance," issued December 29, 2000 (OCC Bulletin 2000-35). The OCC bulletin provides clarification with respect to a number of aspects of the CRA evaluation process, including the frequency and timing of CRA performance evaluations, the applicable CRA performance evaluation period, full-scope and limited-scope reviews, the evaluation of various components of CRA evaluations and the timing for the finalization of CRA performance evaluations when there is an open investigation regarding potential discriminatory or other illegal credit practices. The OCC bulletin also outlines the guidance provided to examiners with respect to CRA evaluations, including the factors to consider in the evaluation process, communication with supervised institutions during the evaluation process and the presentation and analysis of performance data.

The full text of the OCC bulletin is available at: https://www.occ.treas.gov/news-issuances/bulletins/2018/bulletin-2018-17.html.

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