"OCC Improves But Unlevels CRA Ratings" By Warren W. Traiger and Caroline K. Eisner (Banking Exchange)
Banking ExchangeWarren W. Traiger, Caroline K. Eisner
On Oct. 12, the Comptroller’s Office revised its Policies and Procedures Manual to instruct examiners to limit the number of Community Reinvestment Act rating downgrades based on evidence that a bank has violated other laws.
The revision is a boon to national banks and federal savings associations, but places state-chartered institutions at a competitive disadvantage.
Going forward, as more fully explained below, evidence of discriminatory or other illegal credit practices will only result in a CRA rating downgrade for an OCC-regulated bank where there is a “logical nexus” between the rating and the evidence.
Originally published in the Banking Exchange; reprinted with permission.