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NACEDA - Statement on CRA Rule Change

May 21, 2020
NACEDA header

Today, the Office of the Comptroller of the Currency (OCC) announced a final CRA rule with a list of CRA qualifying activities. Comptroller Joseph Otting, the Trump appointee who pushed through this rulemaking, is expected to resign later this week.

“I'm not at all surprised by the reckless speed at which the OCC finalized the rule,” said NACEDA Executive Director Frank Woodruff. “Comptroller Otting has choreographed the illusion of rulemaking since day one, putting forward his misguided single ratio approach over the objections of communities, advocates, banks, and his fellow regulators. I find it exceedingly hard to believe the OCC has carefully considered over 7,500 comments in 41 days while simultaneously managing our country's financial health during a global pandemic.” NACEDA and its members sent a letter to the OCC in late March objecting to CRA rule making during the current pandemic.

The other two regulating agencies — the FDIC and the Federal Reserve — did not adopt the OCC’s regulations. FDIC Chair Jelena McWilliams issued a statement today saying, "the agency is not prepared to finalize the CRA proposal at this time."

“With multiple sets of CRA regulations across agencies, having to know which set of regulations apply to which bank will make the job of serving low- and moderate-income communities harder," Woodruff added. "The fact the FDIC and the Federal Reserve chose not to participate begs Congressional action. When regulators can't agree, Congress steps in to tell them how to agree. It's Civics 101.”

We are diving into the rule with our partners and will provide more information in the weeks and months to come. Go to for news articles and updates. Read NACEDA's full comment letter to the April 2020 NPR.

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