Legal Seminar, Chicago, IL

Comments to the OCC ANPR

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 Themes/Common Perspectives:  Work together! Need joint rulemaking  Increased regulatory clarity and transparent standards  Need more certainty re: CRA-eligible activities  Expand the CRA-eligible activities  Need to modernize for the digital transformation  Update the assessment area definition  Support for metrics-based framework  Subject other financial service providers to the CRA

© 2019 Howard & Howard Attorneys PLLC

FRB Report on Public Feedback

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 FRB Report - “Perspectives from Main Street: Stakeholder Feedback on Modernizing the Community Reinvestment Act”  Summarizes the feedback received from the FRB’s roundtable outreach initiative – 29 roundtables hosted by the FRB and Reserve Banks – October 2018 and January 2019  More than 400 bankers and community group attendees

© 2019 Howard & Howard Attorneys PLLC