What has everyone heard about the timing and content of possible revisions to the CRA regulation, following last summer's public hearings? Someone told me that a new regulatory proposl was expected later this year. Has anyone else heard that, and/or any insights as to the direction the regulators may be heading on the issues they put out for public comment?

Dodd-Franks potentially has significant CRA implications because it defines small business loans differently than the Call Report. I asked a top level FDIC official about the disparity and she told me she thought the CRA definition would be changed to match the DF definition.

Fun fun!

I was at a Fed roundtable a month ago and they asked us (bankers) for input on possible CRA revisions and what we might want to see in a revised regulation. One item that they brought up was requiring by regulation that a bank spend x% of capital on community development activities (they floated 2%). Banks asked for more objective criteria for "community development", more consistent examiner training (this counted last exam, now the EIC of current exam says no), more consideration for small banks for community development-type loans that have to be counted as small business under CRA (ISB has the option to pull those loans out for the CD test), and to take the bank's S&S condition into account when evaluating CRA performance. Example, S&S might have MOU that requires the bank to build capital and cut back on some lending, while the CRA examiners criticize the bank for a lower LTD Ratio and fewer loans. That was something that I always took into account writing CRA and that was preached in my office, but not all examiners do that for some reason.

Those were a few of the highlights. I liked the banks ideas, and despised the Fed comment of requiring the 2% of capital. After my comments, I wouldn't be surprised if I'm not invited back