On November 19, the Bank Policy Institute submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its advance notice of proposed rulemaking, which solicited ideas for building a new regulatory framework to modernize the Community Reinvestment Act (CRA). BPI’s comment letter recommended 13 principles that should guide the agency in its efforts.
BPI’s principles for CRA reform emphasize that:
- It should be based on an assessment methodology that is objective and measurable, and furthers the goals of simplification, transparency, and certainty.
- The CRA framework should accommodate the variety of bank business models, capabilities, and opportunities, as well as changing economic conditions.
- The CRA should include an evaluation method for banks whose business is not clustered in geographies circumscribed by its branches.
- The evaluation regime should be based on the language and purpose of the statute.
BPI’s comment letter also included a range of specific recommendations to put these principles into action.
