Bulletin highlights key changes proposed for CRA regs

A bulletin outlining key proposed changes implementing Community Reinvestment Act (CRA) regulations by three supervisory agencies has been issued by the Office of the Comptroller of the Currency (OCC), noting both highlights and technical amendments.

The OCC, along with the Federal Reserve System Board (FRB) and the Federal Deposit Insurance Corporation (FDIC), have issued a proposed rule for their CRA regulations which amends the definitions of “home mortgage loan” and “consumer loan” to conform with recent changes made by the Consumer Financial Protection Bureau (CFPB) to Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). OCC said the proposed rule would also amend the CRA public file content requirements for consistency with Reg C, make technical amendments to remove cross references related to the proposed amended definitions, and remove an obsolete reference to the Neighborhood Stabilization Program.

According to OCC, highlights of the proposed changes are:

  • alter the definition of “home mortgage loan” in CRA regulations to mean a “closed-end mortgage loan” or an “open-end line of credit” as those terms will be defined under revised Regulation C.
  • remove the term “home equity loan” from the list of consumer loan categories provided under the definition of “consumer loan” in CRA regulations.
  • provide that an institution required to report HMDA data would no longer need to provide its HMDA disclosure statement directly to the public or to maintain the disclosure statement in its public file; rather, the institution would only be required to provide a notice required under new 12 CFR 1003.5(b) of Regulation C, which states that the public may obtain a copy of the disclosure statement from the Consumer Financial Protection Bureau’s website.

Technical amendments, OCC said, would:

  • remove the term “home equity” each time it appears as a category of consumer loans in the CRA regulations.
  • remove an obsolete reference to Regulation C’s Appendix A in the definition of “community development loan” in the CRA regulations.
  • remove an obsolete reference to the Neighborhood Stabilization Program in the definition of “community development” in the CRA regulations.

CFPB’s changes to Reg C take effect Jan. 1 (2018), the OCC bulletin notes, and “will require financial institutions to report applications for, and originations and purchases of, ‘covered loans” that are secured by a dwelling.’”

OCC bulletin: Community Reinvestment Act Regulations – notice of proposed rulemaking