“We welcome the joint proposal from the OCC and FDIC to modernize Community Reinvestment Act regulations. We believe that updating these rules to reflect the reality of financial services today can enhance banks’ ability to invest in their communities and achieve the laudable goals of CRA. We thank Comptroller Otting, Chairman McWilliams and their staffs for their commitment to updating this critically important regulatory framework and their willingness to seek input from all stakeholders, including America’s banks.
“While we have just started to review the proposal with our members, we’re encouraged that it would clarify what qualifies for CRA credit by requiring regulators to develop, publish and periodically update an illustrative list of pre-approved CRA activities that is available to the public. We also appreciate efforts to develop performance standards that will provide greater transparency and consistency as banks plan and execute CRA initiatives. Working with our members, we’ll analyze these standards closely to gauge their likely impact and effectiveness. We look forward to sharing our views, and we will encourage banks to provide their input as well.
“We continue to believe that the nation would be best served by a final interagency rule that also includes the Federal Reserve, which would provide a consistent regulatory framework for all banks. We remain hopeful that any final rule reflects a shared consensus that CRA rules can be modernized in thoughtful ways that promote bank investment and economic growth in the areas that need it most.”