Why the New CRA Rules Won’t Serve Communities Any Better Than the Old CRA Rules

On Tuesday, the banking agencies will release the final version of their 679-page proposal to rewrite the Community Reinvestment Act.  Regrettably, much of the proposal reflected the worst of false-science staff seeking complex new models defining subjective goals combined with certainty-loving compliance officers and lawyers who just want to be told the number they need to hit, not if the number makes any sense.  Unsurprisingly, there were hundreds of comment letters in which banks generally said the agencies should ease up and community groups urged still more stringent standards.  But the story doesn’t end with this unremarkable line-up– in just the last few months, two major bank trade associations and one often-virulently anti-bank advocacy group agreed on one crucial thing:  anything close to what the agencies proposed won’t work.

m102323.pdf