The OCC recently issued 25 FAQs related to its proposal to rescind the June 2020 CRA rule. The FAQs provide information on the rulemaking process and any potential CRA issues that may occur during any transition to the previous 1995 rules.
The main takeaways include:
The 2020 Rule will apply until it is replaced by a different rule. However, the OCC will not use the criteria from the 2020 rule for quantification of qualifying activities, assessment areas, general performance standards, data collection, recordkeeping or reporting. Further, the OCC “will not object” to banks suspending activities intended to comply with parts of the rule that are scheduled to go into effect on January 1, 2023, or January 1, 2024.
An activity that meets the qualifying criteria in effect on the date it is originated, made, purchased, or conducted will remain a qualifying activity, including those activities in targeted areas. However, confirmation letters for qualifying activities under the 2020 rule would apply only while that rule is in effect. Banks should maintain documentation to support the date of an activity and how it qualifies under the 2020 rule or the 1995 rules, as applicable.
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!