Location of Repository

"CRA's 25th Anniversary: The Past, Present, and Future"

By Ph.D. Kenneth H. Thomas

Abstract

This paper focuses on the past, present, and future rules and regulations implementing CRA as developed, applied, and enforced by the federal bank and thrift regulators. The past rules and regulations refer to those in effect during the law's first 18 years, through 1995, when CRA underwent its first major reform. The present CRA rules and regulations were adopted then, with the mandate that they would be reviewed for possible reform in 2002. The future rules and regulations are being drafted now by the regulators, based on their review of approximately 400 public comments; the reform recommendations should be released sometime during the second half of 2002. The future of CRA's legacy as arguably the perfect fair market regulation in a world of Compassionate Capitalism will depend upon the direction of these reforms. Optimal public policy by the bank and thrift regulators in this regard must represent the ideal balance between competing consumer and industry interests. This paper represents the first comprehensive analysis of the public comments and concludes with specific recommendations that will lead to optimal public policy. Creation-Date: 2002-06

OAI identifier:

Suggested articles

Preview

Citations

  1. (2001). 01–18033 Filed 7–18–01; 8:45 am] BILLING CODE 4810–33–P; 6210–01–P; 6714–01–P; 6720–01–P VerDate
  2. (1999). A Transparent Ploy to Hide a Liberal Racket.” The Wall Street Journal.
  3. (1995). Accounting Office.
  4. (2002). Activists Seek CRA Expansion from
  5. (2001). Are the definitions of ‘‘community development’’ and related terms VerDate
  6. (2001). Comments must be received by October 17,
  7. Comments should refer to Docket No. R–1112 and should be mailed to
  8. (2000). Community Reinvestment and Cities: A Literature Review of CRA’s Impact and Future.
  9. (1993). Community Reinvestment Performance.
  10. (2002). Community Ties.” The Regional Economist. St. Louis, Mo.: Federal Reserve Bank of St.
  11. (1999). CRA Activists Bring Protest To Sen.
  12. (2002). CRA Modernization Bill Update.” Reinvestment Works.
  13. (1999). CRA Sunshine report as of October 17, 2001Table 4 Excerpts From Sample ”Sunshine” Filing by Community Group The Greenlining Coalition Fiscal Year Ending November 30,
  14. (2001). Creating a Scorecard for the CRA Service Test: Strengthening Basic Banking Service under the Community Reinvestment Act. Chapel Hill, N.C.:
  15. (2000). Department of Housing and Urban Development, and U.S Department of the Treasury.
  16. (2000). Department of the Treasury.
  17. E-Mail: Send e-mails to regs.comments@ots.treas.gov, Attention Docket No. 2001–49 and include your name and telephone number.
  18. (2001). Facsimiles: Send facsimile transmissions to FAX Number (202) 906–6518, Attention: Docket No.
  19. (1993). Fed Criticizes Clinton Plan On Overhaul Of the CRA.” American Banker.
  20. (2002). Federal Financial Institutions Examination Council.
  21. (2000). Federal Reserve Bank of Cleveland.
  22. (2002). Federal Reserve Bank of San Francisco.
  23. (1996). Governors of the Federal Reserve System.
  24. (2000). Gramm Comments on CRA Lending Report.” Senate Committee on Banking, Housing and Urban Affairs. Press Release.
  25. (2001). Hand deliver comments to the Guard’s Desk, East Lobby Entrance, 1700 G Street, NW., from 9:00 a.m. to 4:00 p.m. on business days, Attention: Regulation Comments, Chief Counsel’s Office, Attention Docket No.
  26. (2001). Insider Enrichment Act.“ Forbes.
  27. (1995). Introduction The Federal financial supervisory agencies are jointly undertaking a review of our CRA regulations, in fulfillment of our commitment to do so when we adopted the current regulations in
  28. (2002). LaFalce Rips OTS Exam Plan As ‘a
  29. (1999). Letter to President Clinton on the Community Reinvestment Act.”
  30. (2000). Minority and Low Income Homeowners More Likely to Receive High Interest Mortgages.” Press Release.
  31. (2002). Office of Comptroller of the Currency.
  32. (2001). Office of Thrift Supervision’s Community Reinvestment Act Performance Evaluations.
  33. Policy Analyst, Compliance Policy, (202) 906– 7990; Theresa
  34. (1994). Public Good Takes a Back Seat In
  35. (1995). ratings reflect the principle that lending is the primary vehicle for meeting a community’s credit needs.
  36. (2002). Reforming Reinvestment.” Letter to the editor. Forbes,
  37. (2000). Reinvestment Coalition.
  38. (2001). Secretary of the Board, Board of Governors of the Federal Reserve System. By order of the Board of Directors. Federal Deposit Insurance Corporation.
  39. Send comments to Regulation Comments, Chief Counsel’s Office, Office of Thrift Supervision,
  40. (2001). Subprime Industry Needs Single Voice to Help Defend Its Image.” American Banker.
  41. (2000). Subprime vs. Predatory Lending.” National Mortgage News.
  42. (2000). Tanoue: Consider Dropping Investment from CRA
  43. (2002). The 25 th Anniversary of the Community Reinvestment Act: Access to Capital in an Evolving Financial System.
  44. (2001). The Community Reinvestment Act After Financial Modernization: A Final Report.
  45. (1997). The Community Reinvestment Act and the Profitability of Mortgage–Oriented Banks.
  46. (1998). The CRA Handbook.
  47. (2001). The Impact of the Growth of Large, Multistate Banking Organizations on Community Bank Profitability, Office of the Comptroller of the Currency.” Economic and Policy Analysis Working
  48. (2000). The Performance and Profitability of CRA–Related Lending.
  49. (2002). The plug should be pulled on the entire strategic plan option, and all banks with approved plans should be evaluated on the basis of their back-up procedures.Table 7 Selected Bank and Thrift Industry Comments on
  50. (2001). this 10th day of
  51. (2001). Wamu Primed for More Subprime.” American Banker.

To submit an update or takedown request for this paper, please submit an Update/Correction/Removal Request.