Earlier this year, the Office of Comptroller of the Currency published an Advance Notice of Proposed Rulemaking (ANPR) asking a series of questions about changes to the current regulatory guidance for CRA. CFA’s comments on this ANPR highlighted a number of concerns with the direction implied by the ANPR’s questions. The most serious concerns raised by CFA relate to a suggestion in the ANPR that the current multi-factor test for CRA compliance that incorporates quantitative and qualitative factors be replaced by a so-called “one metric” test. Experience has shown that CRA investment involves a range of considerations. CFA contends that reducing their impact or importance to some series of numeric values and then relating them to some other numeric value would reduce rather than enhance CRA’s effectiveness.
