The FDIC Board will meet at 3 pm that same day to discuss a CRA final rule.
https://www.fdic.gov/news/board-mat..._medium=email&utm_source=govdelivery

Hang on to your hat!! I am trying to get a copy of the documents to be discussed and voted on.

Here are the links for the FRB meeting this morning:

Meeting Livestream

Board Memo

CRA Fact Sheet

Powell statement in support

Barr statement in support

Bowman statement in opposition

Waller statement in support

The FDIC meeting will be streamed at FDIC Board YouTube Channel.

Is it just me, or has the meeting livestream not started?

It was me! Bank computer is blocking the video. But pulled it up on my phone.

Final Rule in non-Federal Register format is 1494 pages. Happy reading!

Governor Bowman's statement in opposition highlights, I think, potential huge potholes in the road for compliance with the new rule if it is approved.

So when will this all take effect?

DATES: Effective date: This rule is effective on April 1, 2024, except for amendment nos. 26,
49 and 71, which are effective April 1, 2024, through January 1, 2031. The effective date for
amendment nos. 7, 11, 14, 16, 20, 33, 35, 37, 39, 43, 55, 57, 59, 61, and 65 are delayed
indefinitely. The agencies will publish a document in the Federal Register announcing an
effective date for these delayed amendments.

Applicability date: Sections __.12 through __.15; __.17 through __.30; __.42(a); the data
collection and maintenance requirements in § __.42(c), (d), (e), and (f); and appendices A
through F of the common rule text as adopted by the OCC, Board, and FDIC are applicable on
January 1, 2026. Sections __.42(b), (g), (h), and (i) and the reporting requirements in § __.42(c),
(d), (e), and (f) of the common rule text as adopted by the OCC, Board, and FDIC are applicable
on January 1, 2027.

Paraphrased from the Federal Register document:

The final rule implements a revised regulatory framework for the CRA that, like the current framework, is based on bank asset size and business model. This tailoring of the framework recognizes the capacity and resource differences among banks. Under the final rule, banks are classified as either a large bank, an intermediate bank, a small bank, or a limited purpose bank. Pursuant to the final rule: large banks are those with assets of at least $2 billion as of December 31 in both of the prior two calendar years; intermediate banks are those with assets of at least $600 million as of December 31 in both of the prior two calendar years and less than $2 billion as of December 31 in either of the prior two calendar years; and small banks are those with assets of less than $600 million as of December 31 in either of the prior two calendar years. These asset-size thresholds will be adjusted annually for inflation.

In general, the rule becomes effective April 1, 2024. Certain amendments in the rule that refer to the Small Business Loan Reporting requirements in subpart B of CFPB Regulation B (12 C.F.R. part 1002) are delayed indefinitely pending a resolution of the validity and applicability of the Small Business Loan Reporting requirements. The agencies will publish an announcement an effective date for those delayed amendments. One group of selected sections of the common rule text adopted by the agencies will be applicable on January 1, 2026; another group of selected sections of the rule implementing reporting requirements will be applicable on January 1, 2027, with data reporting each April 1, beginning in 2027.

Final section ____.51 of the revised regulations includes transition provisions relating to: applicability of the current CRA regulations; HMDA data disclosures; CRA consideration of eligible loans, investments, services, or products; strategic plans; and a particular ratings standard relating to minimum performance requirements applicable to large banks. Until the applicability dates for these provisions, banks will follow the current CRA regulations, included as appendix G to the revised CRA regulations.

Observations:
The <i>Federal Register</i> submission document is 1,494 pages long. That includes 205 pages reciting the common rule as adopted by the agencies, followed by 223 pages in which each of the agencies spells out revisions to its version of the regulation. New Appendix G, which is a statement of the current regulation of each regulator as of March 31, 2024, is included in each of those three sets of agency revisions.