Impact of Amended Community Reinvestment Act on Intermediate Banks: Final Rules Explained

In a continued shift of banking regulations following an announcement by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, final rules have been laid out for the amendment of the Community Reinvestment Act (CRA). Detailed in a recent blog post from Ballard Spahr LLP
here, the new regulations are projected to have significant implications for different types of banks.

While the guidelines have been explained in a previous post, this analysis particularly highlights the impact on intermediate banks. Defined as those with assets of at least $600 million as of December 31 in the two preceding calendar years, the changes could imply considerable shifts for these institutions.

The “Final Rule”, as it is referred to, was issued on October 24, 2023. Its goal is to amend the regulatory processes for financial institutions, especially with regard to how they serve the communities in which they function. While the implementation of the new CRA is complex, a clear understanding of its implications is crucial for legal professionals advising banks or working in corporate compliances.

This second blog post on the final announcement by the regulators is packed with information that crucially pertains to intermediate banks. As the landscape of banking regulations continues to evolve, understanding the impact of such important measures is necessary for lawyers, compliance officers, and other professionals in the legal sphere.