September 13, 2017

Banking Agencies Propose Clean-Up Amendments to Reconcile CRA Regulations with Regulation C

The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the FDIC (the "Agencies") proposed amendments to their Community Reinvestment Act ("CRA") regulations in response to recent changes made by the Consumer Financial Protection Bureau to Regulation C.

The current proposal would amend the definitions of "consumer loan" and "home mortgage loan" and modify public filing requirements to reconcile them with the corresponding Regulation C changes. The proposal would also remove obsolete references to the "Neighborhood Stabilization Program."

When amending the CRA regulations in 1995, the Agencies relied on the scope of loans reported under Regulation C. Since then, the Agencies have periodically conformed certain definitions in their CRA regulations to the scope of loans reported under Regulation C. The Agencies assert that continuing to do so produces a less burdensome CRA performance evaluation process.