Legal Seminar, Chicago, IL

Recommendations from Treasury

11

 On Exam Process:  Standardize exam schedules  Statuory changes, if necessary, to support more timely evaluations

© 2019 Howard & Howard Attorneys PLLC

Recommendations from Treasury

12

 On Performance:  Adopt uniform guidance re: a logical nexus between a CRA rating and evidence of discriminatory conduct  Don’t delay evaluations pending consumer protection law investigations or enforcement actions  Changes with respect to reviewing bank applications  Clarify that a community benefit plan is one way to demonstrate how a bank will meet the needs of the community

© 2019 Howard & Howard Attorneys PLLC