ICBA supports CRA strategic plan guidance

ICBA said it supports the OCC’s proposed guidance on Community Reinvestment Act Strategic Plans, which is designed to make the strategic plan option more accessible to and less burdensome for community banks.

Details: In a letter to the OCC, ICBA said:

• It supports the OCC’s simplified CRA strategic plan option because it would reduce complexity, increase transparency, and make the strategic plan option more accessible.

• The proposal, by introducing a Simplified Strategic Plan Form, provides a clear, standardized template that streamlines drafting, submission, and OCC review.

• It supports the decision to provide elective example goals drawn from OCC supervisory experience.

• It recommends that the OCC finalize its proposal to limit the use of the Simplified Strategic Plan Form to banks below $30 billion in assets.

Background: The OCC in December issued proposed guidance for a simplified strategic plan process for community banks to comply with the CRA, saying it builds on efforts to reduce burden and tailor examination activities for community banks.

ICBA Resources: ICBA offers various CRA resources for community bankers, including:

• The Community Reinvestment group on ICBA Community, which features more than 800 bankers discussing CRA issues.

• Bank Policies and Procedures: Community Reinvestment.

• The CRA Collaborative Peer Group from ICBA CRA Solutions