http://www.fdic.gov/news/news/press/2013/pr13020.pdf?source=govdelivery

Among other things, the proposed amendments would:

• Clarify how the Agencies consider community development activities that benefit a broader statewide or regional area that includes an institution’s assessment area.
• Provide guidance related to CRA consideration of, and documentation associated with, investments in nationwide funds.
• Clarify the consideration given to certain community development services.
• Address the treatment of qualified investments to organizations that use only a portion of the investment to support a community development purpose.
• Clarify that community development lending should be evaluated in such a way that it may have a positive, neutral, or negative impact on the large institution lending test rating.

I'm surprised that folks have not responded to your post considering the seismic shift that these proposed changes represent. My reservations relat to how the regulators intend to document loans/investments/services conducted outside the AA. Currently these are given "additional consideration". Under the proposed changes, will then receive FULL qualatative credit? Any thoughts?

Unfortunately the reason for the low number of responses is most likely due to the multitude of final regulations weighing on many of our shoulders. A proposal, as important as it may be, has a hard time making it to the top of the stack....at least for me anyway.

I do have issue with the piece on community development loans having a positive, nuetral, or negative impact on a large institute's lending test rating. What will constitute each? It's still up for interpretation, hence possible inconsistancies within the examiners.

There is a lot still open to interpretation with this new "helpful" proposed guidance.