The Community Reinvestment Act (CRA) is a federal law that requires banks to help meet the credit needs of the communities in which they take deposits. It requires periodic evaluation of each bank’s performance. This evaluation is also considered when certain applications are reviewed, such as branches, mergers, and acquisitions. Depending on the size of the bank, it may be required to meet not only a lending test but also tests of its services and investments in its assessment area.
On May 5, 2022, federal bank regulatory agencies jointly issued a proposal to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA) to better achieve the purposes of the law. CRA is a landmark law enacted 45 years ago to encourage banks to help meet the credit needs of their local communities, including low- and moderate-income (LMI) neighborhoods, in a safe and sound manner.
Comment Letter & Template
Comments for the Community Reinvestment Act Proposed Rulemaking are due August 5, 2022. Read IBAT’s comments here.
We have also prepared a sample letter that focuses on key issues identified by our team. We encourage you to use it to file your bank’s comments on or before August 5. The letter requires customized messaging for submission. Additionally, you can submit comments using the IBAT Grassroots Action Center.
Karen Neeley is IBAT General Counsel and leads a CRA task force comprised of IBAT community bankers.
Shay Iacoponelli is President of the IBAT Education Foundation and is leading the charge in our renewed partnership with CRA Partners. We are working together to reduce incidents of crime in area nursing homes, while offering banks the opportunity to earn CRA credit.
Investments, Products and Services
Banks other than those defined as “small” must demonstrate their commitment to Community Reinvestment Act expectations through appropriate investments in qualifying activities. In this page, we have collected information on some of these.
The following are a collection of web sites that should be helpful in understanding CRA and its requirements, as well as in identifying activities that will qualify for CRA credit.
CRA and financial literacy go hand-in-hand. We are often asked by member bankers about opportunities to earn CRA credit through financial literacy, and there are several options that can be helpful. Contact Shay Iacoponelli, President, IBAT Education Foundation for additional guidance.