Proposed OCC and FDIC Geographic Analysis of Home Mortgage and Small Business Lending: Permission to Decrease Lending for the Largest Banks?
Executive Summary The proposed changes to the Community Reinvestment Act (CRA) released by the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) would radically reconfigure the testing criteria for banks. A new testing regime would assess low- and moderate-income (LMI) home mortgage and small business lending with a demographic comparison …
