OCC Issues Guidance for Impact of CRA Ratings on Licensing Applications

November 8, 2017, the Office of the Comptroller of the Currency (OCC) issued this guidance to provide transparency regarding its framework for evaluating certain types of licensing applications.   The guidance outlines the impact of an overall Community Reinvestment Act (CRA) rating of “Needs to Improve” or “Substantial Noncompliance” (together, less than satisfactory CRA performance rating) or a less than satisfactory CRA rating in one or more geographic rating areas, on a bank’s application.

This guidance applies to all national banks, federal savings associations, and federal branches of foreign banks (collectively, banks) that are subject to the CRA. It also applies to state-chartered institutions subject to the CRA that propose to convert to a federal charter.

The OCC regulations implementing the CRA list the application types for which a bank’s CRA rating of performance must be considered in the agency’s review as follows: branch establishment, branch relocation, main or home office relocation, a Bank Merger Act filing involving two insured depository institutions, conversion from state to federal charter, and conversion between federal charters (collectively, covered applications).

When the OCC reviews an application, the facts and circumstances pertaining to the specific transaction dictate whether the OCC will approve or deny the application.

View the OCC Policy and Procedures Manual: 6300-2


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Marissa Blundell, JD, principal, services as CLA Bankers Advisory’s chief operating officer, overseeing all quality control and compliance assessment services. She is a graduate of Skidmore College and New England School of Law. She is admitted to the Massachusetts Bar. Marissa provides compliance training to clients, conducts public training webinars, and speaks at state and regional industry events. She is co-chair of the Massachusetts Mortgage Bankers Association Legislative Committee and is a member of the Mortgage Action Alliance Steering Committee and the national Mortgage Bankers Association's Quality Assurance Committee.

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