CRA Review and Update

WHAT?
It has been years since the federal bank regulatory agencies have overhauled the Community Reinvestment Act (CRA) regulations. Right now, major revisions are unfolding, but in awkward manner.
• On December 12, 2019, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released a Notice of Proposed Rulemaking (NPR) intended to increase bank activity in low- and moderate-income communities where there is significant need for credit, more responsible lending, greater access to banking services, and improvements to critical infrastructure.
• On May 20, 2020, the OCC approved a final rule to modernize the CRA regulations. The final rule is effective on October 1, 2020, but it will be several years before national banks have to fully implement the regulations.
• On September 21, 2020, the Federal Reserve Board (FRB) released an Advanced Notice of Proposed Rulemaking that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks.
• On May 18, 2021, the Office of the OCC published OCC Bulletin 2021-2, which states that the OCC has determined that it will reconsider the final CRA Rule published on June 5, 2020. This is a major step towards achieving uniform revised CRA regulations.
• On July 20, 2021, the FRB, the FDIC, and the OCC jointly announced the agencies are committed to working together to strengthen and modernize regulations implementing the CRA. The OCC separately announced it will propose rescinding the CRA final rule issued in May 2020 and is committed to working with the FRB and the FDIC to put forward a joint rulemaking that strengthens and modernizes the CRA.

WHY?
This program provides a review of the existing CRA rules, the FDIC’s proposed rule, the OCC’s final rule, and an explanation of the Federal Reserve Board’s Advanced Notice of Proposed Rulemaking.
Participants receive a detailed manual that will serve as a handbook long after the program is completed.
PROGRAM CONTENT
This program provides a review of the current, the FDIC’s proposed, the FRB’s advanced proposed, and the OCC final requirements of CRA and its implementing regulations, including:
• Existing, proposed and revised performance tests, standards, and ratings
• Assigned ratings under current, proposed and revised regulations
• Assessment area delineation under the current rule and the new facility-based and deposit-based methods
• New concepts such as retail deposits, retail lending product lines, and qualifying activities lists
• Evaluation concepts such as CRA Evaluation Measures, geographic distribution tests, and borrower distribution tests
• Evaluation options under current, proposed and final rules
• Current data collection requirements and the expanded requirements under the proposed and final rules
• Community Development activities under the current, proposed and revised regulations
• The status of “intermediate small banks.”
(Will the category continue to exist?)
• How small is a “small bank” under existing ($1.305 billion), proposed ($500 million) and revised regulations ($600 million)
• An explanation of the periodic adjustments to the asset-size thresholds used to define “small bank” and “intermediate small bank”
• A review of recent redlining cases
• A review of the CRA Questions and Answers, exam results and CRA agreements
• Public file requirements
• CRA notices
• An explanation of how to obtain community development credit for COVID-19-related activities
• The status of the proposed and final revisions to the regulations

WHO?
The program is designed for loan officers, compliance officers, CRA officers, loan department staff, bank counsel, and auditors. Whether new to the requirements of the CRA and its regulations or a seasoned veteran, this program provides a comprehensive review of the rapidly changing requirements of the CRA.

Schedule
8:45 a.m.—Registration
9:00 a.m.—Program begins
Noon—Lunch
1:00 p.m.—Program begins
4:00 p.m.—Adjourn

Continuing Education Credit
Attendees qualify for 6.5 hours Continuing Professional Education (CPE) credit in the area of Specialized Knowledge.

Virtual Learning
TBA’s Virtual Live Training option allows for one participant per paid registration. The paid registration gives access to program resources for effective learning.
If additional attendees would like access to the program resources (including but not limited to online link/connection, program manuals, and interaction with the facilitator/speaker) an additional paid registration is required. We appreciate your assistance in ensuring that each event participant is registered with TBA and all applicable fees are paid. This will help our organization continue to provide exceptional resources to its members. CPEs and attendance records are kept for all programs. In order to receive documentation for completion of TBA programming, participants must be registered and complete the interactive activities during the Virtual Live program.

Delivery Method and
Program Level/Content
This is a live, group internet-based overview program. There are no prerequisites or advanced preparation needed. Each participant will receive a manual as a reference guide with vital information participants can use every day. The instructor will take time to discuss and answer questions that participants may have and will share important and practical information concerning the tax returns. Each participant should bring a calculator to class.