The Interagency Community Reinvestment Act Final Rule: Eight Things for Large Banks to Know

The Interagency Community Reinvestment Act Final Rule: Eight Things for Large Banks to Know

November 2, 2023, Covington Alert

On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency released a final rule to overhaul the agencies’ regulatory framework for evaluating banks’ performance under the Community Reinvestment Act (“CRA”). The final rule concludes a rulemaking process stretching back more than five years, following a 2022 interagency notice of proposed rulemaking and an earlier, abandoned effort by the OCC to make changes to its own CRA rules. The final rule makes the most significant interagency changes to the agencies’ CRA regulations in more than 25 years, and will substantially alter CRA compliance obligations for banks of varying sizes and business models. This client alert provides key takeaways for large banks, which the final rule defines as banks with $2 billion or more in assets.