OCC Finalizes Overhaul Of Community Lending Rules

OCC Finalizes Overhaul Of Community Lending Rules

May 20, 2020, Law360

Randy Benjenk spoke with Law360 about the Office of the Comptroller of the Currency’s overhaul of bank regulations of lending to low-income and underserved communities. The rulemaking document still leaves some open questions, including what specific numerical thresholds and benchmarks banks will be judged against under the revised grading methodology. Mr. Benjenk says without those numbers banks will find it "very hard, if not impossible" to know how they will fare under the agency's new grading framework. He adds, “It's a little bit like moving into a building where the exterior is done, but it doesn't yet have a floor plan. That uncertainty creates a significant question as to how banks will be transitioned from the current framework to the new framework because banks need to know how much activity they should be preparing to do to get a satisfactory score.”

He also notes that deferring the decision on those metrics also raises the possibility that a new comptroller could approach this calibration process with different priorities.