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OCC CRA Final Rule: What’s Next for the FDIC and Federal Reserve Board?

CFPB Monitor

When the OCC issued its final Community Reinvestment Act (“CRA”) rule on May 20, 2020, the agency acted alone without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued its proposed rule. As to the Federal Reserve Board (“FRB”), it had already bowed out of the CRA reform effort in 2019.

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OCC Highlights, AML & CRA Risks

Perficient

Additionally, the recent rule by the OCC, the Federal Reserve, and the FDIC strengthens and modernizes Community Reinvestment Act (CRA) regulations. The effective date of the new rule is April 1, 2024, with key provisions taking effect on January 1, 2026, and January 1, 2027. 

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OCC and FDIC issue proposed rules to undo Madden

CFPB Monitor

The OCC and FDIC issued proposed rules this week intended to eliminate the uncertainty created by the Second Circuit’s decision in Madden v. Comments on the OCC’s proposal must be submitted by January 21, 2020. With regard to interest rate authority, the OCC points to Section 85 (applicable to national banks) and 12 U.S.C.

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OCC, FDIC, and Federal Reserve propose amendments to CRA regulations

CFPB Monitor

After moving alone in 2020 to reform its Community Reinvestment Act (CRA) regulation, the Office of the Comptroller of the Currency (OCC) has joined the Federal Deposit Insurance Corporation (FDIC) and Federal Reserve Board in issuing a joint notice of proposed rulemaking setting forth proposed amendments to their regulations implementing the CRA.

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OCC and FDIC issue joint proposal to revise CRA regulations; Ballard Spahr to hold Jan. 29 webinar

CFPB Monitor

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join the proposal and presumably will issue a separate proposal. On January 29, 2020, from 12 p.m.

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California Dept. of Business Oversight launches “true lender” investigation of auto title lender’s partnership with Utah bank

CFPB Monitor

In 2019, California enacted AB-539, the Fair Access to Credit Act (FACA), which, effective January 1, 2020, limits the interest rate that can be charged on loans of $2,500 to $10,000 by lenders licensed under the California Financing Law (CFL) to 36% plus the federal funds rate. The FDIC has not yet proposed a similar rule.

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CARES Act includes provisions affecting financial institutions and their regulation: some key provisions

CFPB Monitor

Section 4008 of the CARES Act authorizes the Federal Deposit Insurance Corporation (FDIC) to establish a debt guarantee program to guarantee the debt of solvent insured depository institutions and depository institution holding companies. All such programs shall terminate not later than December 31, 2020.