ARTICLE
19 October 2018

FRB Governor Recommends Improvements To Community Reinvestment Act

CW
Cadwalader, Wickersham & Taft LLP

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Federal Reserve Board ("FRB") Governor Lael Brainard outlined a number of ways to improve the effectiveness of the Community Reinvestment Act ("CRA") ...
United States Finance and Banking

Federal Reserve Board ("FRB") Governor Lael Brainard outlined a number of ways to improve the effectiveness of the Community Reinvestment Act ("CRA") and to increase availabile credit in lower-income areas.

In remarks at a roundtable on community investment, Ms. Brainard recommended:

  • updating the "assessment area" concept;
  • tailoring CRA regulations to address banks with different sizes and business models;
  • encouraging banks to expand services in underserved areas; and
  • improving consistency and predictability in CRA evaluations and ratings.

Additionally, Ms. Brainard encouraged the public submission of comments to the Office of the Comptroller of the Currency ("OCC") in response to the recent Advanced Notice of Proposed Rulemaking ("ANPR") relating to revising CRA regulations. Ms. Brainard noted that while the FRB did not join in the publication of the OCC's ANPR, it would be reading the comments in anticipation of working with the OCC and the FDIC in a joint proposal.

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