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Course description

WHAT?

It has been 27 years since the federal bank regulatory agencies have overhauled the Community Reinvestment Act (CRA) regulations. Right now major revisions are unfolding after several false starts over the past four years. On May 5, 2022, the agencies jointly issued a proposal to strengthen and modernize regulations implementing the CRA. The agencies accepted comments on the 619-page proposal until August 5, 2022. Now the agencies are thrashing through the comments letters. Soon we will see what the multi-year revision process has wrought.

The new regulations will be effective on the first day of the first calendar quarter that begins at least 60 days after the publication date of the final rules. The effective dates for certain sections are delayed for one or two years after publication of the final rule. 

WHY?

This program provides a review of the agencies’ new proposed rule, and comparisons to the existing and prior proposed rules. The direction of the final rule is becoming clearer. Participants will better be able to start planning implementation of the rules once final.

 

Participants receive a detailed manual that serves as a handbook long after the program is completed.

TOPICS

Upon completion of the program, participants will understand the new rule and the comments submitted on various aspects of the proposal, including:

  • Bank size categories (small (< $600 million), intermediate (≥$600 million and < $2 billion) and large (≥ $2 billion)) are clearly divided, with no overlaps.
  • Large bank exams have evolved substantially. Large banks receive the Retail Lending Test, the Retail Services and Products Test, the Community Development Financing Test, and the Community Development Services Test. Small bank are examined using the current process but have the option to use a Retail Lending Test. Intermediate banks are subjected to a Retail Lending Test, and either community development performance standards or a Community Development Financing Test.
  • Assessment areas will be defined using a facilities–based assessment area (similar to the current method), a new retail lending assessment area (for large banks), and areas for eligible community development activity.
  • The agencies will maintain a publicly available illustrative list of non-exhaustive examples of community development activities that qualify for CRA consideration.
  • The agencies will use different performance tests and standards to assess a bank’s CRA performance:
  1. The Retail Lending Test for large and intermediate banks. The test also includes screens and metrics.
  2. The Retail Services and Products Test for large and intermediate banks.
  3. The Community Development Financing Test for large and intermediate banks. The test includes metrics and benchmarks.
  4. The Community Development Services Test for large banks. The test includes metrics.
  5. The Community Development Financing Test for Wholesale or Limited Purpose Banks.
  6. The small bank performance standards.
  7. The intermediate bank community development performance standards.
  8. Standards in a strategic plan.
  • Data collection and reporting continues to be required for large banks.

WHO?

The program is designed for loan officers, compliance officers, CRA officers, loan department staff, bank counsel and auditors.  Whether new to the requirements of the CRA and its regulations or a seasoned veteran, this program provides a comprehensive review of the rapidly changing requirements of the CRA.

Instructor(s)

Jack Holzknecht and Kimberly Boatwright

Jack Holzknecht is the Founder of and a Senior Consultant at Compliance Resource, LLC. He has been delivering the word on lending compliance for 46 years. In 41 years as a trainer over 155,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. Kimberly Boatwright is EVP and Director of Risk and Compliance at Compliance Resource, LLC and has more than a two decades of experience working in the financial services industry. Ms. Boatwright is a well-regarded financial industry risk and compliance professional with a strong background in program development and implementation. She is a thought leader who specializes in Fair Lending, Anti-Money Laundering, OFAC and consumer compliance. During her career she has worked for and consulted with all types of financial institutions helping to establish and evolve compliance and risk programs. She is a frequent public speaker, trainer, and author on compliance and risk management topics. Kimberly is a Certified Regulatory Compliance Manager and a Certified Anti-Money Laundering Specialist

Course curriculum

  • 1

    Webinar

    • Access Webinar

  • 2

    Materials

    • Slides

    • Materials

    • Questions and Answers

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