In this report, we expand our initial analysis of the CRA rule finalized by the OCC shortly before Comptroller Otting’s departure.  This report is in lieu of an in-depth analysis in our Financial Services Management format because we do not think the rule as finalized will be practically implemented by most national banks due to delayed timelines, many outstanding questions set for future OCC guidance that may or may not come, legal challenge, and overarching political uncertainty.

The full report is available to retainer clients. To find out how you can sign up for the service, click here.