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CRA Final Rule Recently Published

Learn about the recently released CRA final rule and potential operational impacts for banks.
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CRA Updates

On February 1, 2024, the FDIC, Office of the Comptroller of the Currency, and the Federal Reserve published the final rule for the Community Reinvestment Act of 1977 (CRA) in the Federal Register. The published rule contains minor, immaterial edits to the requirements outlined in the October 24, 2023 drafted rule. However, the published rule provides specific date applicability for the first evaluation of large banks under the amended performance standards. Large banks evaluated on or after February 1, 2024 may not receive a “Satisfactory” or “Outstanding” rating unless an overall facility-based assessment area conclusion of “Low Satisfactory” is received in 60% or more of all facility-based assessment areas in a state or multistate MSA, or nationwide, as applicable.

The agencies took a phased approach to the applicability of the requirements, allowing institutions time to implement necessary changes. Thankfully, only a handful of changes impact operations on the effective date of April 1, 2024. The most high-impact of which is the requirement to publish the institution’s public file digitally on their website if one is maintained. This requirement is applicable regardless of the institution’s size or prudential regulator.

As of this publication, there are approximately 21 months before the next phase is applicable. However, it’s not too early to start preparing yourself and senior management on what to expect moving forward. Developing an implementation plan and drafting a program now could potentially save some headaches in the coming months.

More CRA Resources

Be on the lookout for our May 2 webinar, “Familiarizing Yourself With CRA Performance Evaluations,” as we delve into each section of the rule. In addition, join us on September 9–12 for our 2024 Regulatory Compliance Conference in Destin/Miramar Beach, Florida, where we will discuss the rule requirements in depth and how you can prepare for the changes.

If you have any questions or need assistance, please reach out to a professional at FORVIS.

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