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ARTICLE · 25 JUNE 2018

OCC Clarifies Supervisory Policy And Processes For CRA Exams

Hogan Lovells Cadwalader
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The Office of the Comptroller of the Currency ("OCC") notified national banks, federal savings associations, and federal branches and agencies of clarifications to the OCC ...

United StatesFinance and Banking

The Office of the Comptroller of the Currency ("OCC") notified national banks, federal savings associations, and federal branches and agencies of clarifications to the OCC supervisory policies and processes for Community Reinvestment Act ("CRA") exams. The policies and processes apply to the evaluations of all OCC-supervised banks subject to the CRA.

The policy clarifications addressed certain aspects of the CRA exam process, including:

  • full-scope and limited-scope reviews;
  • "size" and "purpose" tests for activities that promote economic development;
  • the use of demographic, aggregate and market share data for banks that report under the Home Mortgage Disclosure Act;

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