Consumer Finance Monitor

The FDIC’s and OCC’s Proposed CRA Reform: What the Agencies Consider Now in CRA Evaluations and How That Would Change


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We are joined by Diego Zuluaga, a Cato Institute policy analyst, for a discussion of the proposed changes. After reviewing the current regulatory framework, we examine the proposal's new qualifying activities criteria and approach to "branchless banking" in determining assessment areas, respond to criticism of its approach to public projects, look at the small bank opt-out and what in the proposal should be revisited, and consider the impact of the Fed's non-participation.

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Consumer Finance MonitorBy Ballard Spahr LLP

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