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#2252275 - 04/13/21 01:31 PM New rules for OCC intermediate bank
dottiec Offline
Gold Star
Joined: Jul 2007
Posts: 305
We have just completed our CRA exam covering 2018, 2019, and 2020.

I understand the compliance date for the new CRA rules is January 1, 2024 for us, so our exam covering 2021, 2022 and 2023 will take place after the Jan 1 date.

Am I correct that the only change from this exam would be that CRA activities will be assessed under the new rules? We can still use our partial county assessment area and do not have to keep records of our deposit accounts for that exam. We would start using the expanded assessment area and keep the deposit records required going forward for our exam covering 2024, 2025, and 2026.
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#2252298 - 04/13/21 04:22 PM Re: New rules for OCC intermediate bank dottiec
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
Below are the relevant compliance dates if you are a small bank or Intermediate Bank. Having provided the information below I am confident that the OCC 2020 CRA Rule will be changed within the year, so I wouldn't get too anxious about complying with the 2020 Rule at this time.

§ 25.01: (7) Compliance dates
(iii) Small and intermediate banks must comply with §§ 25.09, 25.22, and 25.25, as applicable, by January 1, 2024.

§25.09 - AA delineation

.§ 25.22 Retail domestic deposit data collection for small and intermediate banks evaluated under the small and intermediate bank performance standards in § 25.14.
A small or intermediate bank evaluated under the small and intermediate bank performance standards in § 25.14 must collect and maintain data on the value of each retail domestic deposit account and the physical address of each depositor as of the close of business on the last day of each quarter during the examination period until the completion of its next CRA evaluation

§ 25.25 Recordkeeping - Banks must keep the data collected under § 25.21, § 25.22, and § 25.23 in machine-readable form (as prescribed by the OCC) until the completion of their next CRA evaluation.

§ 25.21 pertains to banks subject to the general performance standards (i;e., Large Banks), and § 25.22 is quoted above and § 25.23 pertains to wholesale and limited purpose banks
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#2252301 - 04/13/21 04:42 PM Re: New rules for OCC intermediate bank dottiec
dottiec Offline
Gold Star
Joined: Jul 2007
Posts: 305
Thank you
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