Joint Statement on CRA Consideration for Activities in Response to COVID-19

  • Source: fdic.gov

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Article Highlights:

On March 19, 2020, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC, jointly Agencies) issued a Joint Statement CRA Consideration for Activities in Response to COVID-10 (Joint Statement). The Agencies recognize the potential for the coronavirus pandemic to have significantly adverse effects on bank customers, especially low- and moderate-income (LMI) customers, and encourage institutions to meet the financial services needs of the affected people and areas.  The Agencies will provide favorable CRA consideration of certain retail banking and lending activities and community development activities in response to the pandemic for the period of the national emergency plus six months after the emergency declaration is lifted.

The Agencies encouraged financial institutions to work with affected customers, particularly low- and moderate-income customer, small businesses, and small farms, in a manner that is both safe and sound and responsive to community needs. Activities that will receive favorable CRA consideration include, but are not limited to:

  1. Waiving fees, such as ATM and overdraft fees, early withdrawal fees on time deposits, and late payment fees on loans;
  2. Easing check cashing restrictions on out-of-state or non-customer checks;
  3. Expanding access to credit by increasing credit card limits and offering short-term unsecured credit products for creditworthy borrowers;
  4. Providing alternate service options, such as mobile apps, online banking, and phone banking; and
  5. Offering payment flexibility through options such as extensions, deferrals, and skip-a-pay, if these do not incur negative credit reporting.

The Agencies remind institutions that they may receive Community Reinvestment Act consideration for community development loans, investments, or services that revitalize or stabilize their assessment areas or the states or regions that includes their assessment areas. Examples of such activities include, but are not limited to, loans, investments, and services that:

  1. Support digital services for LMI individuals or communities;
  2. Support access to healthcare, especially for LMI individuals or communities;
  3. Sustain small business operations; and
  4. Provide food supplies and services for LMI individuals or communities.

Author

Lynn Woosley

Lynn Woosley is a Senior Director with Treliant.  She is a seasoned executive with extensive risk management experience in regulatory compliance, consumer and commercial credit risk, credit and compliance risk modeling, model governance, regulatory change management, acquisition due diligence, and operational risk in both financial services and regulatory environments.