On December 2, the OCC posted its schedule of Community Reinvestment Act (CRA) evaluations to be conducted in the first quarter of 2017. In a press release accompanying the 2017 schedule, the OCC encouraged public comment on the national banks and federal savings associations scheduled to be evaluated, and suggested that “comments be submitted to the institutions themselves at the mailing addresses listed on the schedule, or to the appropriate OCC supervisory office prior to—or as early as possible during—the month in which the evaluation is scheduled.” The OCC will consider all public comments received prior to the close of the CRA evaluation.
On December 19, the Federal Financial Institutions Examination Council (FFIEC) posted the 2017 version of its Community Reinvestment Act (CRA) Data Entry Software. This software—which is intended to help automate the filing of CRA data—is year-specific, i.e., 2016 reporting requires the 2016 version, not the 2017 version. In November, the FFIEC clarified that it was discontinuing its HMDA Data Entry Software and instead requiring that filers submit HMDA data collected in 2017 using a web interface called the “HMDA Platform.”
The Federal Reserve Bank of Philadelphia has posted the latest edition of Consumer Compliance Outlook. This edition features articles on subpart B of Regulation E on Remittance Transfers and the updated interagency questions and answers regarding Community Reinvestment.
On October 25, the National Community Reinvestment Coalition and community groups across the country sent a letter to the OCC explaining that they strongly oppose the consideration of a limited-purpose fintech charter by the bank regulator. The groups explained that they would consider supporting the limited-purpose chartering of a fintech firm “only if the OCC does not preempt strong state law and establishes vigorous supervision and regulation for the newly chartered institutions.” Additionally, the groups want chartered fintech firms to be subject to “rigorous Community Reinvestment Act (CRA)-like obligations” and “stringent” safety and soundness reviews. The letter argues that “new charter and receivership authority for uninsured institutions, primarily financial technology companies (fintechs), has the potential to benefit consumers and communities,” but only if accompanied by CRA-like obligations, and supervision and examination to ensure compliance with both fair lending and consumer protection laws.
On August 18, the OCC, the FDIC, and the Federal Reserve announced the availability of a 2015 data fact sheet on small business, small farm, and community development lending as reported by certain commercial banks and savings associations pursuant to the Community Reinvestment Act (CRA). Less comprehensive than the data reported pursuant to the Home Mortgage Disclosure Act, the CRA data includes the number and dollar amount of community development loans and small business and small farm loans originated or purchased. It also indicates whether a small business or farm loan is extended to a borrower with yearly revenues of $1 million or less and combines those loans into three categories based on size, which are reported at a census tract level. CRA data does not cover loan applications that were denied or applicant demographic information, and it is not completed on a loan-by-loan basis. According to the data fact sheet, “caution should be used in drawing conclusions from analyses using only CRA data, as differences in loan volume across areas may reflect differences in local demand for credit.”