Community Reinvestment Act: OCC Issues Advance Notice of Proposed Rulemaking to Improve the Regulatory Framework Implementing the Community Reinvestment Act

Sullivan & Cromwell LLP - September 4, 2018

On August 28, the Office of the Comptroller of the Currency published an advance notice of proposed rulemaking (the “ANPR”) soliciting “ideas for building a new framework to transform or modernize the regulations that implement the Community Reinvestment Act of 1977 [(“CRA”)].” The ANPR does not propose specific revisions to the current CRA regulations, which were last materially revised in 1995, but requests comment on a series of questions that appear designed to inform the OCC on the scope and desirability of possible changes. The ANPR indicates that these changes could range from relatively minor updates of the current CRA regime to a major overhaul in approach that could significantly affect the actions of banks in lending, investing, and providing other banking services in low- and moderate-income geographies.