On July 14, the Federal Reserve Bank of Minneapolis hosted a virtual discussion and listening session on how Community Reinvestment Act (CRA) proposed rulemaking could more effectively address the investment and credit needs of community development financial institutions (CDFIs), minority depository institutions (MDIs), and low-income credit unions (LICUs).
A primer on the CRA Molly Majerle, Federal Reserve Bank of Minneapolis
10:20–10:35 a.m. CT
Highlights of CDFI-, MDI-, and LICU-related provisions in the CRA Notice of Proposed Rulemaking Michou Kokodoko, Federal Reserve Bank of Minneapolis
10:35–11:15 a.m. CT
Audience discussion of key issues relating to CDFIs, MDIs, and LICUs From the Notice of Proposed Rulemaking:
Should the agencies [the Federal Reserve, OCC, and FDIC] also include in the MDI definition insured credit unions considered to be MDIs by the National Credit Union Administration?
Should the agencies consider activities undertaken by an MDI or WDI [women’s depository institution] to promote its own sustainability and profitability? If so, should additional eligibility criteria be considered to ensure investments will more directly benefit low- and moderate-income and other underserved communities?
Should the proposed factor focused on activities supporting MDIs, WDIs, LICUs, and Treasury Department-certified CDFIs exclude placements of short-term deposits, and should any other activities be excluded? Should the criterion specifically emphasize equity investments, long-term debt financing, donations, and services, and should other activities be emphasized?
Should the agencies provide more specific guidance regarding what credit products and programs may be considered especially responsive, or is it preferable to provide general criteria so as not to discourage a bank from pursuing impactful and responsive activities that may deviate from the specific examples?
Facilitated by Michou Kokodoko and Michael Grover, Federal Reserve Bank of Minneapolis
11:15 a.m. CT
Your feedback on the modernization process will help us ensure that regulatory changes lead to a more effective CRA. We encourage you to voice your comments and questions about the modernization proposal during this important conversation. You are also welcome to provide written comments about the proposal at any time before August 5, 2022.