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Compliance Companion®
Standard Proceedure Manuals (SPM)

Community Reinvestment Act November 2022

Our BCG Community Reinvestment Act Manual is a comprehensive guide to compliance with the federal banking agencies’ CRA regulations. It provides separate discussions of the various performance evaluation methods, the Strategic Plan option, assessment area delineation, the role of the performance context in performance evaluations, and the public CRA disclosure requirements. The Manual describes the Lending Test for small banks and intermediate small banks (ISB), the Community Development Test for ISBs, the Community Development Test for wholesale and limited-purpose banks, and guides large banks through the Lending, Investment and Service Test criteria, as well as the related data collection and reporting requirements. Moreover, the Manual addresses the agencies’ CRA Sunshine Regulations. New this year, the Manual provides an high-level overview of the interagency CRA proposed rule that is still pending as of November 2022.

In addition to covering all aspects of CRA compliance, SPM #15 provides a detailed discussion of compliance with HMDA and Regulation C, including the 2020 changes to the loan-volume criteria for determining whether a depository institution is subject to Regulation C. Additionally, SPM #15 discusses the recent case of National Community Reinvestment Coalition v. CFPB, in which the U.S. District Court for the District of Columbia partially granted the plaintiffs’ motion for summary judgment, invalidating the 2020 rule, which increased the closed-end mortgage reporting threshold to 100, as arbitrary and capricious.

The Manual includes detailed information regarding –

  • How to prepare for your next CRA examination
  • CRA resources
  • Developing a bank’s performance context
  • How to delineate an assessment area
  • Small bank and intermediate small bank performance standards
  • Large bank performance standards
  • Community development test for wholesale and limited-purpose banks
  • Strategic plan option and why every bank should at least consider adopting one
  • Data collection and reporting requirements for large banks
  • Public CRA disclosure rules, including the required contents of a bank’s CRA public file and HMDA public file
  • CRA sunshine regulations
  • HMDA and Regulation C — the changes that became effective January 1, 2018, including the new data points to be collected, and the new partial exemptions from reporting certain data points for small-volume lenders, as well as the new loan-volume criteria for determining whether a depository institution is subject to Regulation C

The text of this Manual is 405 pages, plus 55 pages of appendices.


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SPM 15
* Janet Bonnefin is retired from the practice of law with the firm.
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