After what has seemed like an endless series of irregular periods of action, the OCC, Federal Reserve, and FDIC have finally issued their long-awaited amendments to the Community Reinvestment Act (CRA) regulations.

Banking has come a long way since 1977, when the original CRA regulations were issued – we’ve seen the evolution into the incredible new array of digital products and services and major changes in the way those products and services are delivered.

But the core concepts of the CRA remain: banks are evaluated on their performance within their communities, particularly on the lending side, with a particular focus on Low- and Moderate-Income (LMI) areas within its assessment area. The CRA regulations have long needed to be updated to reflect the new realities of banking, and we finally know what those responsibilities are. However, we’ve seen some important differences from the Proposed Rule that we must understand and incorporate.

As expected, the compliance responsibilities are divided into three distinct categories, depending on bank asset size: small, intermediate, and large. The larger a bank is, the more changes to its CRA responsibilities it will see. But change will impact all banks to some degree.

The litigation against the agencies’ new rule alleges supposed “overreach.” What is likely to happen, and when? Will the rules be revoked (unlikely, but you never know)? Will they be changed (possibly)?

We’ll also address the state of CRA today – what is necessary to achieve an Outstanding (or Satisfactory) rating? We’ll be living with the current CRA regulations for likely a few more years, so it’s important to understand what it takes to succeed today, as well as plan for the future.