Following opposition to the OCC’s CRA rewrite, the FRB has proposed an initial construct that takes some elements of the OCC’s approach and adds further and in some cases different provisions to craft what the Fed hopes will become an inter-agency CRA construct in 2021. An extremely long ANPR seeking views on 99 questions, the Fed’s proposal is clearly an initial foray into a new CRA framework, not a penultimate policy statement.
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