Four hundred pages of proposed CRA rule changes landed this summer, and the CRA community continues to sift through the details and implications. The short version: the OCC and the FDIC would move the asset thresholds that determine a bank’s size, rewrite the tests that banks of every size have to pass, and change what counts as community development work.
Comments close October 13.
We asked two people who sat on opposite sides of the exam table to read it with us. Donna Murphy served as Deputy Comptroller of the OCC. Kevin Moss was the Chief Risk Officer at SoFi and spent 17 years at Wells Fargo managing credit, compliance, and operating risk for consumer lending. Donna and Kevin join FairPlay’s General Counsel, Abby Hogan, a former regulator and banker.
| Related: Watch Episode 1 the CRA / FYI series: A Former Regulator’s Take on the Proposed CRA Rule Changes
Where CRAi fits
The proposed rules raise important questions that will shift the trajectory of some institutions. Which threshold category does my bank land in? What happens to my rating if my bank is recategorized? Where does my bank sit against my peers? FairPlay’s CRAi is the tool for this analysis. CRAi reads more than 80,000 CRA performance evaluations along with 25 public data sources, providing a comparative analysis of your institution between today’s rule and those proposed in the new rules.
Run your institution against the proposed rules at fairplay.ai/crai.
