Fed CRA plan seen as bridging divide with OCC

Randy Benjenk is quoted in the American Banker regarding the Federal Reserve's proposal to modernize the Community Reinvestment Act, which could bridge the divide with the OCC. Mr. Benjenk says that some provisions of the Fed’s outline are “strikingly similar to the OCC’s final rule, either in concept or execution.” He adds, “The commonalities may be a reflection of points on which the agencies agreed during the interagency discussions that took place before the OCC issued its proposal. They may also be the result of the Federal Reserve having the opportunity to leverage aspects of the OCC’s final rule and industry and community group feedback on that rule.”

He went on to say, “A key question is whether the OCC will be willing to slow the pace of implementing its rule to allow time for it to consider joining the Federal Reserve in further changes without requiring banks to overhaul their compliance systems twice.”

Conceptually, there are enough similarities in the two agencies’ approaches to think that the agencies could find common ground if they were motivated to do so,” Mr. Benjenk says. “However, if the OCC now decides to try to find middle ground, there are enough technical differences between the approaches that the OCC likely would need to engage in a new rulemaking process to harmonize the standards.”