Initial NCRC Analysis of OCC Proposal to Establish Thresholds for its New CRA Measures
The OCC has proposed yet another data collection effort to develop thresholds for its flawed 2020 Community Reinvestment Act final rule. This is another tacit admission by the OCC that all along it has lacked the data and factual basis for developing its flawed revisions to CRA examination performance measures. Instead of creating more consistency …
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