"Technical" Corrections to the New CRA

Slipped into the Christmas rush was yet more regulatory activity on CRA. This action was a seasonal clarification of several technical points to explain when certain new provisions take effect for banks opting for different examination procedures.

The short version of these technical corrections is that banks must comply totally with either the new regulation or the old one. This implementation process covers posters, public files, and data compilation and reporting. Banks may not use a combination of rules. The reasoning is simple: the technical requirements in the new rule are designed to support the new examination process.

Banks that do not comply with new technical requirements will not be able to support an examination under the new rules. Data and other information needed to answer examiners questions would not be available. Without that, examiners will have to proceed under the old regulation.

Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 3, 1/96