The Massachusetts Community & Banking Council, Inc. (MCBC) submitted a comment letter to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) in response to the notice of proposed rule making to reform the Community Reinvestment Act (CRA).

The proposed regulations are extensive and attempt to:

• clarify which activities qualify for CRA credit,
• update where activities count for CRA credit,
• create a new method for measuring CRA performance, and
• change CRA-related data collection, recordkeeping, and reporting.

MCBC’s letter supports the suspension of federal rule-making projects that aren’t directly related to the COVID-19 pandemic. Once this national emergency is behind us, MCBC encourages the OCC and the FDIC to work with the Federal Reserve Bank to establish one policy framework that:

• establishes two distinct tests for CRA-eligible activities – retail lending and community development;
• determines benchmarks for each AA based on local demographics and the aggregate lending of other in-market competitors;
• develops of a national database whereby each bank can track its activity against thresholds on an ongoing basis using current data; and community partners can access and understand CRA performance trends in real time.

MCBC feels strongly that it is more important to get CRA modernization right than to get it done quickly.

Wednesday, April 8th, 2020 is the end of the comment period for the CRA Modernization NPR. We encourage you to submit comments:

To the OCC, click here.

To the FDIC, click here.