Federal Reserve Board ("FRB") Governor Lael Brainard summarized comment letters submitted by academics, banks, banking trade associations, community and consumer groups, related to the Office of the Comptroller of the Currency's proposed rulemaking to reform the Community Reinvestment Act ("CRA").
In remarks before the "Research Symposium on the Community Reinvestment Act," sponsored by the Federal Reserve Bank of Philadelphia, Ms. Brainard noted that commenters, community and consumer groups:
- applauded the volume of CRA loans and investments that support low-and-moderate income households and communities;
- provided recommendations about modernizing the procedures for evaluating a bank's CRA activities;
- offered input on tailoring CRA regulations to banks of various sizes and business models (i.e., CRA regulations cannot be "one-size-fits-all");
- proposed suggestions on modernization of assessment areas to better achieve the "goal of encouraging banks to seek out opportunities in underserved areas";
- recommended how to increase the "consistency and predictability of CRA evaluations and ratings"; and
- emphasized the "historical context of the CRA as it relates to redlining practices."
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