The OCC and FDIC issued a joint proposal for the overhaul of the Community Reinvestment Act last month while the Federal Reserve issued their own proposal this week, sharply critical of the OCC-FDIC proposal; one of the most important differences centers around the concept of a single ratio for compliance; In a recent speech Fed governor Lael Brainard said, “Dividing evaluations into separate retail and community development tests is important. In contrast, an approach that combines all activity together runs the risk of encouraging some institutions to meet expectations primarily through a few large community development loans or investments rather than meeting local needs.” American Banker
