After the Final Rule was released in October of 2023, we all seem to find ourselves asking this same question, what now?
Navigating the new rule while finishing strong with the current rule can seem daunting. This guide will help CRA Professionals as well as Chief Risk Officers in formulating a plan for regulatory change and provide the key risks to consider with questions to discuss with your team.
5 Steps to Navigating Regulatory Change
Step #1: Read the Rule
On October 24th, 2023, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) jointly issued a final rule amending the Community Reinvestment Act (CRA). Regulators continue to enhance their focus on oversight, supervision, and enforcement and CRA is no exception. Increased scrutiny is expected in the coming years.
Step #2: Publish Your Public File Online by April 1, 2024
While many sections of the new rule have compliance dates set for 2026 and 2027, there are a few sections that are applicable April 1, 2024. In particular, banks must update and publish their public file on their external website by April 1, 2024.
The image to the right illustrates the sections that are effective by April 2024 and what areas the bank should focus on that will help begin the transition.
Step #3: Finish Strong with the Current Rule
With at least one more examination left under the current rules, it is important to take time to strengthen your bank’s current CRA program before approaching the new rule. Here are some steps to focus on to solidify your program now.
Step #4: Brief Your Executives and Have Strategic Conversations
Brief your executive management and have strategic discussions with key stakeholders to address the key risks associated with CRA modernization.
Strategic Risk
Compliance Risk
Operational/Financial Risk
Reputation Risk
Step #5: Join the CRA Hub
The CRA Hub is a membership designed to offer structured guidance around running CRA programs. CRA Hub creates clarity around the technical aspects of the CRA, and builds a community of community development professionals across the nation.
In the Hub we will help you navigate regulatory change and implement the final CRA rule.
