On May 5, 2022, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) proposed to jointly amend their regulations implementing the Community Reinvestment Act (CRA) to update how CRA activities qualify for consideration, where CRA activities are considered, and how CRA activities are evaluated.
CRA reform is a complicated issue with lots of nuances. That is why we have relied on NACEDA, our national trade association, for a draft document that focuses specifically on our field. All you need to do is review the letter and, if you agree with its comments, add your organizational information, put it on your letterhead and save it as a PDF. Then just send it in, following the instructions below.
You should deliver your comment letter separately to each of the three regulating agencies. All three allow you to upload a file. Here’s what you need to do.
OCC:
After you click on this link: https://www.regulations.gov/commenton/OCC-2022-0002-0001. you will see a form and can either type in comments directly and/or upload a file.
FDIC:
Email: comments@fdic.gov. Include RIN 3064-AF81 on the subject line of the message.
Federal Reserve Board:
Email: regs.comments@federalreserve.gov. Include Docket No. R-1769 and RIN 7100-AG29 in the subject line of the message.
Please send me an email when you’ve sent your letters so we can keep track. As before when talking about reforms to CRA, the number of comments they receive really does matter. IF YOU HAVE TROUBLE OPENING THE DOCUMENT, EMAIL ME AND I’LL SEND IT TO YOU DIRECTLY.
Thanks for all you do – stay safe, stay strong and keep healthy.
Terry Chelikowsky
Executive Director
Florida Alliance for Community Solutions
