A Look at the Joint Community Reinvestment Act Proposal Issued by the OCC, FDIC, and Federal Reserve Board, with Special Guest Kenneth Thomas, President of Community Development Fund Advisors, LLC
Mr. Thomas is widely-viewed as the nation’s leading CRA expert and has advised federal regulators on CRA reform. After reviewing CRA’s origins and purpose, we discuss how the new proposal differs from the OCC’s rescinded 2020 final CRA rule and the current CRA rules, including the proposal’s higher asset threshold for small banks and approach to assessment areas, how industry and consumer groups have reacted to the proposal, and next steps and possible timetable for issuance of final rules. We also discuss state efforts to enact CRA-like laws and the concept that the CFPB should have a role in approving bank mergers.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation joined by Scott Coleman, a partner in the firm’s Consumer Financial Services Group.