Alternative Approach to CRA Modernization Articulated by Federal Reserve Board Governor

Dafina Williams

Yesterday, Federal Reserve Board Governor Lael Brainard gave a speech at the Urban Institute outlining a vision for reforming the Community Reinvestment Act (CRA) regulations that differs significantly from the proposal put forward last month by the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC).

Of particular note, the proposal rejects the central design feature of the OCC-FDIC proposal whereby the dollar value of a bank’s CRA eligible activities divided by the size of the bank plays a primary role in determining the bank’s overall CRA rating. 

Brainard’s CRA speech comes as the clock starts ticking for comments on the OCC and FDIC’s CRA reform proposal. The Federal Reserve notably chose not to join the OCC and FDIC in their Notice of Proposed Rulemaking, formally published in the Federal Register on January 9, 2020. Comments are due to those two agencies by March 9, 2020.

It is unclear if the Federal Reserve will move forward with its own Notice of Proposed Rulemaking to seek public input on its proposal, but Governor Brainard highlighted the importance of the bank regulators continuing to operate in a joint regulatory framework to enforce CRA. 

The debate over the future of CRA is now in full swing. Stay tuned for more updates about how you can advocate for reforms that ensure CRA continues to provide critical capital and investment in underserved communities. For more information on OFN’s CRA advocacy, please contact Dafina Williams ( or Jennifer Vasiloff (

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