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On August 28, 2018, the Office of the Comptroller of the Currency (OCC) released an Advance Notice of Proposed Rulemaking (ANPR) to seek stakeholder comments on the modernization of the Community Reinvestment Act (CRA). Comments are due 75 days after the issuance of this ANPR.
The OCC is looking to modernize the regulations that implement the CRA in order to better achieve the statute’s original purpose, increase lending and investment where it is needed most, and reduce the burden associated with reporting and assessing CRA performance. The ANPR solicits comment on a number of questions regarding improvements to the CRA regulations related to:
- increasing lending and services to people and in areas that need it most, including in low- and moderate-income areas;
- clarifying and expanding the types of activities eligible for CRA consideration;
- revisiting how assessment areas are defined and used;
- establishing metric-based thresholds for CRA ratings;
- making bank CRA performance more transparent;
- improving the timeliness of regulatory decisions related to CRA; and
- reducing the cost and burden related to evaluating performance under the CRA.
The AHTCC will be providing feedback to urge that any changes to the CRA continue to support robust investment in the Low-Income Housing Tax Credit and a healthy affordable housing delivery system. If you have any questions, contact Emily Cadik, Executive Director, at emily.cadik@taxcreditcoalition.org.
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