- On October 19. The Fed terminated a Cease and Desist Order against Citibank issued May 20, 2015 related to deficient policies and procedures that prevented Citigroup from detecting and addressing unsafe and unsound conduct by the Bank’s FX sales personnel.
- On October 20, the Fed launched a data collection initiative to gather information from banks affected by the large bank capital change proposal published in September. The information is being requested to allow the Fed to clarify the estimated effects of the proposal. The deadline for submission of the data is January 16, 2024.
- On October 24, the OCC, Fed, and FDIC announced finalized principles for Climate-related financial risk management for large banks with $100 billion or more in total assets. The principles, which are consistent with existing rules and guidance, cover governance; policies, procedures and limits; risk management; data, risk measurement, and reporting; strategic planning, and scenario analysis.
- On October 24, the OCC, Fed, and FDIC announced interagency final rulemaking for revisions to the Community Reinvestment Act to “better achieve the CRA’s core purpose of encouraging banks to help meet the credit needs of their local communities.” Key elements of the final rule included:
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- Four new CRA performance tests for large banks (assets of $2 billion or more): The Retail Lending test, Retail Services and Products Test, Community Development Services Test, and Community Development Financing Test.
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- Intermediate banks (assets of at least $600 million but less than $2 billion) will be subject to the new Retail Lending Test and, at the bank’s option, either the new Community Development Financing Test or the current Community Development Test.
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- Small banks (assets less than $600 million) have the option of remaining with the current small bank performance test or using the new Retail Lending Test.
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- Limited purpose banks will be subject to the Community Development Financing Test for Limited Purpose Banks.
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- Community development activities were clarified by an update to the definition of community development, developing an interagency list of qualifying community development activities, and providing a process that will allow banks to request confirmation that an activity qualifies as a community development activity.
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- Updating and streamlining data collection, maintenance and reporting requirements for large banks.
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Contact us to learn how a strategic partnership with Doran Jones can provide you with cost-effective solutions by leveraging our expertise with these and other critical risk and compliance functions.