Several days ago, the Federal Reserve posted a notice for comment on the amended CRA regulation. It does not appear to have hit the Federal Register yet. Does anyone have a feel for when it will, or what the proposed changes include?

Not that I am impatient or anything...

I know a couple of weeks ago the FDIC supported this Notice of Proposed Rulemaking and that the other agencies would eventually follow suit (sounds like FED is now "in"). I THINK (?) the proposal appears in the Federal Register for a 60-day comment period when all agencies come forward with support. Not sure of the whole timing deal.

The proposed changes in the broadest terms are:

1. Small bank definition to go from $250MM to $500MM with no test for part of a holding company...each bank on its own,

2. Any evidence of dicriminatory, abuse lending patterns will negatively affect your CRA rating (dah!), but I think this makes it an "official" position",

3. Some additional detail (number and amount of small biz/farm by CT(?)) added to the public disclosure statements required by large banks.

Number 1 is going to supply all the excitement and entertainment over the next year or two.......... Most commiunity bankers are going to be all supportive, but the consumer groups are going to be out of their minds in rage! It will be great fun, only in America will we see such passion over an issue like this! Gotta love it.

I was looking to see small bank defination include small CREDIT UNIONS! (heh heh) Actually I'd like that to include large credit unions as well. I'm tired of seeing them walk like a duck and not have to report like one! (That and I'm thinking the job opportunities for CRA officers would nearly tripple) heh heh, leverage...it's a good thing!

The proposal is in the 2/6/04 issue of the Federal Register. Click here to access the proposed rule. It is 19 pages long. The reason it is so long is they discuss the comment letters they received in response to the ANPRM and explain why they are not proposing to change certain items. What they are proposing to change does mirror what the press releases said.

Anyone have a comment letter draft they'd be willing to share? Feel free to PM if you'd rather not post to the world. Thanks in advance -