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From Banking and Finance Law Daily, July 15, 2016

Updated community reinvestment FAQs published

By Richard A. Roth, J.D.

The Federal Reserve Board, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation are revising their interagency questions and answers on the Community Reinvestment Act. According to the agencies, six new questions and answers are being added to the interagency FAQs and nine others are being substantively revised. Technical revisions are being made to an additional 25 Q&As, the interagency notice says.

The interagency FAQs, which were first published in 1996, are intended to help financial institutions, agency employees, and the public understand the agencies' CRA regulations. The new revisions address comments made in response to a September 2014 proposal (see Banking and Finance Law Daily, Sept. 8, 2014). The agencies say that affected Q&As relate to:

  • the availability and effectiveness of a bank’s retail banking services;
  • the innovativeness and flexibility of a bank’s lending practices;
  • a bank’s community development loans and services; and
  • the responsiveness and innovativeness of a bank’s loans, investments, and services.

Intent of changes. The 2014 proposal noted that the new and revised FAQs were intended to give more consideration to ways that banks could offer services without relying on brick-and-mortar branches and by using innovative credit products.

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