Legal Seminar, Chicago, IL

OCC ANPR

15

 Questions re: Current CRA Framework include:  Are regulations clear and easy to understand?  Applied consistently?  Objective, fair and transparent?  What aspects of the current framework are successful? Worth retaining?

© 2019 Howard & Howard Attorneys PLLC

OCC ANPR

16

 Questions re: a Modernized CRA focused on:  Revising the current approach, generally  Establishing a metrics-based approach  Redefining communities and assessment areas  Expanding types and categories of CRA-qualifying activities  Defining community and economic development  How to promote transparency and consistency in recordkeeping, reporting and exam requirements

© 2019 Howard & Howard Attorneys PLLC