Building on an advance notice of proposed rulemaking (ANPR) from the Office of the Comptroller of the Currency, the OCC and FDIC have now proposed specific changes to Community Reinvestment Act (CRA) regulation. The Federal Reserve has not yet joined this proposal, reflecting the controversy it has engendered despite widespread agreement that CRA rules – last substantively updated in 1995 – need modernization. The NPR is particularly focused on the shift in recent years to banking without reliance on physical offices, a market change that complicates determining the CRA “assessment” area in which a bank gathers deposits to judge community credit and development activities.
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