OCC Improves But Unlevels CRA Ratings

Banking Exchange
6 minute read | November.03.2017

On Oct. 12, the Comptroller’s Office revised its Policies and Procedures Manual to instruct examiners to limit the number of Community Reinvestment Act rating downgrades based on evidence that a bank has violated other laws.

The revision is a boon to national banks and federal savings associations, but places state-chartered institutions at a competitive disadvantage.

Going forward, as more fully explained below, evidence of discriminatory or other illegal credit practices will only result in a CRA rating downgrade for an OCC-regulated bank where there is a “logical nexus” between the rating and the evidence.

Originally published in the Banking Exchange; reprinted with permission.