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Excerpt from Joint Notice of Public Hearings; Request for Comment on the
Community Reinvestment Act Regulations
Topics and Questions
The agencies invite testimony on, and are particularly interested in receiving
written comments on, the following topics and questions:
Geographic coverage. What are the best approaches to evaluating the
geographic scope of depository institution lending, investment and/or deposit-taking
activities under CRA? Should geographic scope differ for institutions that are traditional
branch-based retail institutions compared to institutions with limited or no physical
deposit-taking facilities? Should it differ for small local institutions compared to
institutions with a nationwide customer base? If so, how? As the financial services
industry continues to evolve and use new technologies to serve customers, how should
the agencies adapt their CRA evaluations of urban and rural communities?
CRA performance tests, asset thresholds and designations. Should the
agencies revise the criteria used to assess performance under the current CRA tests: small
institution; intermediate small institution; large institution; “wholesale and limited
purpose” institution or strategic plan? Are the current asset thresholds that apply to
institutions and tests appropriate?
Affiliate activities. Currently, the agencies consider affiliate activities only at the
request of the related depository institution. Should the agencies revise the regulation
and, instead, require that examiners routinely consider activities by affiliates? If so,
what affiliates or activities should be reviewed? How should consideration of affiliates
affect the geographic coverage of CRA assessments?
Small business and consumer lending evaluations and data. Should the
agencies revise the evaluation of and/or data requirements for small business and small
farm lending activities or for consumer lending activities, including activities or products
designed to meet the needs of low- and moderate-income consumers? If so, what
changes are needed?
Access to banking services. How should access to financial services be
considered under CRA? What changes would encourage financial institutions to expand
access to un-banked and under-banked consumers in a safe and sound manner and to
promote affordable, safe transaction and savings accounts? Should the agencies revise
CRA to include additional regulatory incentives to provide access to services for
historically underserved and distressed areas?
Community development. What are the opportunities to better encourage
community development loans, investments and services to support projects that have a
significant impact on a neighborhood? Should the agencies consider revisions to the
Community Development Test or to the definition of community development? How

could the rules most effectively balance support for community development
organizations of different sizes, varying geographic scope, and in diverse rural and urban
communities? How might they balance incentives for meeting local needs as well as the
needs of very distressed areas or those with emergency conditions?
Ratings and incentives. Is there an opportunity to improve the rules governing
CRA ratings to differentiate strong, mediocre, and inadequate CRA performance more
consistently and effectively? Are there more effective measures to assess the qualitative
elements of an institution’s performance? Are there regulatory incentives that could be
considered to encourage and recognize those institutions with superior CRA
performance?
Effect of evidence of discriminatory or other illegal credit practices on CRA
Performance Evaluations. Currently, the agencies’ evaluations of CRA performance
are adversely affected by evidence of lending discrimination or other illegal credit
practices as outlined in the CRA rules. Are the existing standards adequate? Should the
regulations require the agencies to consider violations of additional consumer laws, such
as the Truth in Savings Act, the Electronic Fund Transfer Act, and the Fair Credit
Reporting Act? Should the regulations be revised to more specifically address how
evidence of unsafe and unsound lending practices adversely affects CRA ratings?
CRA disclosures and Performance Evaluations. Should the agencies consider
changes to data collection, reporting, and disclosure requirements, for example, on
community development loans and investments? What changes to public Performance
Evaluations would streamline the reports, simplify compliance, improve consistency and
enhance clarity? Should the agencies consider changes to how Performance Evaluations
incorporate information from community contacts or public comments?