More Banks Will Need CRA Strategic Plans

Answered by:

Question:

We heard that some banks would be required to submit strategic plans under the revised rule. Is this true?

Answer:

Yes. The revised rule states:
“Plan submission (1) Required submission. A bank must submit a strategic plan that meets the requirements of this section if the bank:
• Would otherwise be evaluated under § 345.12 (banks not being evaluated as small banks) and does not maintain retail domestic deposits on-balance sheet; or
• Is a small bank that does not originate retail loans.

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Learn more about Kathleen Blanchard’s webinar CRA Modernization Proposal Review