Community Reinvestment Act Policy
This Community Reinvestment Act Policy addresses policies, procedures and processes for a bank or savings association to ensure proper adherence to the provisions and intent of the Community Reinvestment Act (“CRA” or “the Act”) in order to meet the goals of the credit needs of the communities the organization serves, including low- and moderate-income neighborhoods.
NOTE: Due to the final rule announced on 10/24/23 having multiple future applicability dates, including some which are delayed indefinitely until further notice from the federal regulatory agencies, clients placing an order for this product will receive two different versions of the Community Reinvestment Act Policy Template:
Community Reinvestment Act Policy Template – Prior Rule Version. The contents of this version are applicable up to 03/31/24 and beyond as the regulatory agencies release additional guidance regarding the effective dates of the final rule and other changes:
Table of Contents
- Purpose and Contents – Topic 1
- Policy Statement – Topic 2
- Structure of Accountability – Topic 3
- Definitions – Topic 4
- Audit Policy – Topic 5
- Staff Training – Topic 6
- Retention of Documentation – Topic 7
Subpart B – Standards for Assessing Performance
- Performance Tests, Standards and Ratings – Topic 1
- Lending Test – Topic 2
- Investment Test – Topic 3
- Service Test – Topic 4
- Community Development Test for Wholesale or Limited Purpose Banks – Topic 5
- Small Bank and Intermediate Small Bank Performance Standards – Topic 6
- Strategic Plan – Topic 7
- Assigned Ratings – Topic 8
- Effect of CRA Performance on Applications – Topic 9
Subpart C – Records, Reporting, and Disclosure Requirements
- Assessment Area Delineation – Topic 1
- Data Collection, Reporting and Disclosure – Topic 2
- Content and Availability of Public File – Topic 3
- Public Notice – Topic 4
- Publication of Planned Examination Schedule – Topic 5
Subpart D – Transition Provisions
- Consideration of Bank Activities – Topic 1
- Strategic Plan Retention – Topic 2
Subpart E – Prohibition Against Use of Interstate Branches Primarily for Deposit Production
- Purpose and Scope – Topic 1
- Loan-to-Deposit Ratio Screen – Topic 2
- Credit Needs Determination – Topic 3
- Sanctions – Topic 4
Community Reinvestment Act Policy Template – New Rule Version.
This version contains all of the guidance contained in the final rule announced on 10/24/23, including applicability dates for various topics, subtopics, paragraphs, bullet points, etc., where appropriate, to help your financial institution implement changes on April 1, 2024 in addition to those in the future. Most of the final rule’s requirements will be applicable beginning January 1, 2026. The remaining requirements, including the data reporting requirements, will be applicable on January 1, 2027. We will revise this version in response to federal regulatory agency notices regarding revisions to the “delayed indefinitely” notations within the product, in addition to other applicable federal regulatory guidance issued under CRA:
Table of Contents
- Purpose and Contents – Topic 1
- Policy Statement – Topic 2
- Structure of Accountability – Topic 3
- Definitions – Topic 4
- Consideration of Community Development Loans, Investments and Services – Topic 5
- Community Development Illustrative List – Confirmation of Eligibility – Topic 6
- Impact and Responsiveness Review – Topic 7
- Audit Policy – Topic 8
- Staff Training – Topic 9
- Retention of Documentation – Topic 10
Subpart B – Geographic Considerations
- Facility-Based Assessment Areas – Topic 1
- Retail Lending Assessment Areas – Topic 2
- Outside Retail Lending Areas – Topic 3
- Areas for Eligible Community Development Loans, Investments, and Services – Topic 4
Subpart C – Standards for Assessing Performance
- Evaluation of CRA Performance – Topic 1
- Retail Lending Test – Topic 2
- Retail Services and Products Test – Topic 3
- Community Development Financing Test – Topic 4
- Community Development Services Test – Topic 5
- Limited Purpose Banks – Topic 6
- Strategic Plan – Topic 7
- Assigned Conclusions and Ratings – Topic 8
- Small Bank Performance Evaluation – Topic 9
- Intermediate Bank Performance Evaluation – Topic 10
- Effect of CRA Performance on Applications – Topic 11
Subpart D – Records, Reporting, Disclosure, and Public File Engagement Requirements
- Data Collection, Reporting, and Disclosure – Topic 1
- Content and Availability of Public File – Topic 2
- Public Notice – Topic 3
- Publication of Planned Examination Schedule – Topic 4
- Public Engagement – Topic 5
Subpart E – Transition Rules
- Applicability Dates and Transition Provisions – Topic 1
Subpart F – Prohibition Against Use of Interstate Branches Primarily for Deposit Production
- Purpose and Scope – Topic 1
- Loan-to-Deposit Ratio Screen – Topic 2
- Credit Needs Determination – Topic 3
- Sanctions – Topic 4
Includes the following form templates:
CRA Notices – 12 pages
CRA Ratings – 36 pages
Recent updates to this product:
04/01/24 Update
Joint Release – Agencies Extend Applicability Date of Certain Provisions of Their Community Reinvestment Act Final Rule
01/02/24 Update
Joint Release – Joint Final Rule: Technical Amendment
OCC Bulletin 2023-40 – Community Reinvestment Act: Revision of Small and Intermediate Small Bank and Savings Association Asset Thresholds
12/04/23 Update
Joint Press Release – Agencies Issue Final Rule to Strengthen and Modernize Community Reinvestment Act Regulations
01/03/23 Update
Joint Release – Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions
02/15/22 Update
OCC Bulletin 2022-2 – State Community Reinvestment Laws; Consumer Complaint: Input from State Officials and Consumer Complaint Referrals from States
01/03/22 Update
Joint Release – Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions
This Community Reinvestment Act Policy (approximately 32 and 76 pages, respectively) is available to purchase from BankPolicies.com in Microsoft® Word format.
