What specifically of the amended CRA rules takes effect 10-1-20 for OCC banks???

All of them unless you qualify for a delayed implementation.

Ok, and where does it discuss qualifications of the delayed implementation element?

https://www.occ.gov/news-issuances/federal-register/2020/nr-occ-2020-63a.pdf

Start at the bottom of Page 194

Thank you! We are a "small bank" under CRA, so we have until 1-1-24 to comply with these provisions, if I'm reading this correctly??

yes the small banks and intermediate banks have until 1/1/2024 if you don't opt into the new tests (what banker in their right mind would do that?). I think the new rule is very impractical and many changes will be needed. I've identified a number of errors that need correction and issues that need clarification. The OCC is due to release proposed amendments and guidance in October, so let's see what they come up with.

If a bank were to jump thru unnecessary hoops to comply today, I agree the bank would be creating work and jumping thru revised hoops for probably several iterations of the new rules in the future. The CRA rules were rushed and as the FRB comes out with its own revised rules, we could anticipate the FDIC will and the possibility that the three will later get more in sync. (Don't laugh, it could happen.)

Andy, we can only hope that they come together. I've never seen anything like this in all my time in compliance. Three agencies all on divergent paths. The OCC leading the charge and then the director forcing something quickly and stepping out of the space!

I can't wait until the election is over, a new OCC head honcho takes over, and LIKELY gets on board with the way the Fed has outlined things. Then I believe that the FDIC will come on board too.

The new OCC rule revises Appendix B, the CRA Notice (different language, adding email addresses to contact info). I cannot find if the branch version of the CRA Notice has also been changed. Is anyone aware if the branch notice has also been changed and, if so, what the new verbiage is?

It is on page 371 and 372

The new rule no longer requires a different version of the CRA notice for branches. The recent OCC proposed CRA benchmarking rule also proposes a change to the CRA notice. See page 11 of the following. https://www.occ.gov/news-issuances/federal-register/2020/85fr78258.pdf

We had an unexpected changeover in staff and the new public file and CRA Notice items have been overlooked....

Just want to verify that we no longer have a separate "branch file" just the one main public file....is that correct?

Questions: For both the CRA Notice (and HMDA disclosure) it states they can be posted electronically....if they are posted on a TV screen that rotates information, do you think that would be sufficient? OR should they be a fixed posting?

Another question....I don't understand the additional information we need to make available as stated in the notice....isn't everything that they may request in the public file by regulation?