A proposal by the Office of the Comptroller of the Currency to make Community Reinvestment Act strategic plans more accessible for community banks is increasingly important as the institutions pursue fintech partnerships and niche lending strategies that often do not align neatly with the traditional CRA framework, the American Bankers Association said in a letter to the agency.
Currently, any bank may elect to have the OCC assess its CRA performance under an approved strategic plan rather than CRA’s standardized performance tests. The agency is proposing to make strategic plans more accessible by providing more detailed guidance on the measurable goals and other components for institutions with up to $30 billion in assets. It is also proposing to simplify the method for drafting and submitting a proposed strategic plan.
ABA called the proposal an important step forward “and signals that the OCC intends to encourage broader community bank use of the strategic plan option.” Still, the association had several recommendations to clarify the elective goals that a community bank could include in a proposed strategic plan. ABA also supported revising the consultation process to allow the OCC to provide preliminary feedback on the adequacy of a draft strategic plan.
In addition, ABA recommended that the public participation process be amended to give greater weight to public comments from individuals and entities within the bank’s assessment area, and that a bank would not be required to revise its draft plan unless public comments raise substantive, community-specific issues within its assessment area. It also recommended that the OCC adopt additional procedures to avoid making successive requests for additional information that result in a proposed plan being deemed incomplete.
