Community Reinvestment Act (CRA) Modernization

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  • Peter Dugas, Elizabeth Rozsa, Elanna Kooistra
  • Published: 27 January 2023


While the FDIC, OCC, and FRB work aggressively to finalize the proposed rule issued on May 5, 2022, modernizing the CRA, the impact to large banks (assets of $2 billion or greater) promises to be significant.  
With performance to become tied to new a standard known as Retail Lending Assessment Areas and overall performance to be evaluated under four tests - Retail Lending Test, Retail Products and Services Test, Community Development Financing Test, and Community Development Services Test - now is the time for large banks to be planning for compliance.  
In addition to preparing for a host of new data collection and reporting requirements, changes to a bank's current CRA performance strategy may be required to achieve at least a satisfactory rating given the new thresholds, metrics, and tests. 
Read more in our latest paper.