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Modernizing the Community Reinvestment Act: New Proposed Regulations

New CRA Approaches to Online and Mobile Banking, Data Collection, Bank Size, and Capability

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, November 2, 2022

Recorded event now available

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This CLE course will examine a new joint proposal by the federal banking agencies to modernize the Community Reinvestment Act (CRA) regulations. The panel will discuss how the rise of mobile and online banking would be addressed in the new regs, how compliance obligations might vary depending on bank size and location, and steps bank and non-bank lenders should take in anticipation of the proposed changes to the CRA.


On May 5, 2022, the Federal Reserve System, the FDIC, and the Office of the Comptroller of the Currency (OCC) issued a joint proposal to "strengthen and modernize regulations" implementing the CRA. Last updated in 1995, the CRA regulations encourage FDIC-insured institutions to serve low- and moderate-income (LMI) communities. With this new proposal, regulators seek to introduce more flexibility in how banks can meet their obligations.

Among other objectives, the joint proposal would update the CRA regulations to adapt to changes in the banking industry, including the expanded role of mobile and online banking; provide greater clarity and consistency in the application of the CRA regulations; and tailor performance standards of accounting for differences in bank size, business models, and local conditions.

Bank and non-bank lenders should consider whether their current digital banking platforms would comply with the new regulations and review their lending data to assess how they serve LMI communities, especially communities of color and Native Americans. Banks should also evaluate their size category since compliance obligations will vary under revised asset-size thresholds.

Listen as our authoritative panel discusses the proposed CRA revisions and how they might impact the lending practices of both small and large banks.



  1. Community Reinvestment Act: current regulatory framework and why it is outdated
  2. Key aspects of the joint proposal
    1. Adapts to changes in the banking industry, including expanded mobile and online banking
    2. Provides greater clarity and consistency in the application of the CRA regulations
    3. Performance standards differ depending on bank size, business models, and local conditions
    4. Data collection and reporting requirements and use of existing data
    5. Transparency and public engagement
    6. CRA and fair lending responsibilities are mutually reinforcing
    7. Creates a consistent regulatory approach that applies to banks regulated by all three agencies
  3. Actions banking institutions should take now


The panel will review these and other issues:

  • In what respects has the CRA become outdated, given the changes in the delivery of banking services?
  • How can mobile and online banking be used to satisfy a bank's CRA performance obligations?
  • In what respects do performance standards differ for more extensive and smaller financial institutions under the new regs?
  • What actions should banks take now to ensure that their data collection and reporting practices comply with the new CRA regs?


Bisanz, Matthew
Matthew Bisanz

Mayer Brown

Mr. Bisanz counsels domestic and global financial services firms on a variety of banking and derivatives regulatory...  |  Read More

Dempsey, Natasha
Natasha Dempsey

Senior Attorney
Goodwin Procter

Ms. Dempsey is a senior attorney in the firm’s Financial Industry group and Consumer Financial Services, Fintech...  |  Read More

Nunn, Robin
Robin Nunn

Morgan, Lewis & Bockius

Ms. Nunn is Co-Leader of the firm’s Banking Industry Team. Her practice focuses on complex civil litigation,...  |  Read More

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