CRA: Federal v. State

Several states have CRA laws. Some of these are modeled on the federal law, but others carry additional requirements and measurements. Although nationally chartered financial institutions such as national banks are often exempt from state laws that conflict with federal laws, the Riegle-Neal IBBEA of 1994 subjects banks to the community reinvestment laws of the state or states in which they have a branch.

To clarify their approach, the OCC has issued an Advisory Letter, AL 98-17, reminding institutions that it has the authority to examine and enforce compliance with the applicable state CRA law. In such states, examiners will contact state banking commissioners for information about the bank's compliance with state CRA law.

Affected states include Connecticut, Massachusetts, New York, Rhode Island, Washington, West Virginia, and the District of Columbia.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 4, No. 1, 2/98