Interagency finalization of revamped CRA sets the table for noteworthy changes
The recent finalization of an updated Community Reinvestment Act (CRA) reflects longstanding efforts to address an evolution in banking practices since the Act’s inception in 1977, including the introduction of new product delivery technologies and customer behaviors. But with input incorporated into the regulations from a range of stakeholders including federal agencies, industry and community leaders, complying with the new CRA requirements will require significant adaptation, according to expert commentary by Wolters Kluwer Compliance Solutions.
“Every bank is going to be touched by this in some way, no matter the size of the bank. This changes the status quo for everybody,” said Timothy Burniston, Senior Advisor, Regulatory Strategy at Wolters Kluwer Compliance Solutions.
Burniston’s insights on finalization of a modernized CRA, were featured in a National Mortgage Professional magazine article, “Federal Reserve Approves Major CRA Overhaul After Nearly Three Decades” on the same day interagency finalization was achieved. The regulation is being published in the Federal Register and takes effect April 1, 2024, with key provisions becoming applicable on January 1, 2024.
Burniston recommends that in addition to carefully reading the final rule and supplementary information, banks first consider how they may be affected by changes to assessment areas and CRA-eligible activities.
“Understanding geographically where you’re going to be evaluated and determining if there are areas where you are not currently being evaluated but will be in the future, is an essential first step in trying to understand how this rule will impact your bank most,” he notes.
Among the significant changes reflected in the final rule—compared to the proposed rule—is the extension of the implementation period from one year to two years. Burniston says that it will be important for regulators to keep the CRA regulations responsive to short- and long-term disruptions and current with continuing changes within the banking industry as the implementation process moves forward. The final rule also makes adjustments to other substantive provisions such as retail lending assessment areas, retail lending performance ranges, major product lines, and how automobile lending will be considered in performance evaluations.
National Mortgage Professional is published by American Business Media. It reaches 58,000 readers and is dedicated to helping professionals progress their understanding of the residential mortgage banking business – particularly in the areas of strategy, operations and compliance.
