The OCC Goes Solo on CRA: What's in the Final Rule, Which Banks Does it Cover, and Will it Stand?

Webinar | June.16.2020 | 2pm - 3pm (Eastern Daylight Time)

The Office of the Comptroller of the Currency recently announced a final rule that it says will modernize the Community Reinvestment Act, culminating a three-year effort to revamp the law's 25-year-old regulatory framework. The rule marks the first time that the OCC has staked out sweeping changes to CRA compliance without support from the Federal Reserve and the Federal Deposit Insurance Corporation. Compliance with the new rule, which takes effect Oct. 1, is required over the next two to three years.

Orrick attorney Warren Traiger who assisted the Consumer Bankers Association and individual banks in analyzing and commenting on the modernization proposal that led to the final rule, discussed the substance of the rule, including how it differs from the proposal and current law; which banks are impacted; and potential political and legal obstacles to its implementation.