Community Reinvestment Act: The Final Regulations and What Banks Need to Know Now

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Community Reinvestment Act: Final Regulations and What Banks Need to Know Now

Webinar | November.28.2023 | 3pm - 4pm (Eastern Standard Time)

Zoom – Recording Available

The Community Reinvestment Act (CRA) was enacted to confront redlining and encourage banks to help meet the credit needs of their communities, especially low- and moderate-income neighborhoods. On October 24, 2023, the Federal Reserve, OCC and FDIC jointly promulgated regulations that significantly overhaul the way they enforce the CRA. Characterized as “modernization,” the New Rule replaces the regulatory scheme implemented in the mid-1990s and will significantly impact CRA compliance.

In conjunction with the Mortgage Bankers Association, Orrick attorneys Warren Traiger and Victoria Freitag held an in-depth discussion on November 28 on the effects of the New Rule. This discussion covered compliance and enforcement issues,
including:

What Retail Lending Assessment Areas and Outside Retail Lending Areas are and how they are created
How banks will be evaluated under the rule, including a breakdown of scoring under the new four-part assessment mechanism
How “major product lines” are determined and assessed under the Retail Lending Test
How the rule impacts consideration of home mortgages and mortgage-backed securities
How community development activities are assessed and how impact and responsiveness are considered
The timeframe for data collection, benchmarks and metrics, reporting, and performance evaluations

View the presentation materials

Speakers

Victoria Freitag Associate, Public Finance, Strategic Advisory & Government Enforcement (SAGE)

San Francisco

See my bio

D:+1 415 773 4508
E: [email protected]

Practice:

Finance Sector
Public Finance
Strategic Advisory & Government Enforcement (SAGE)

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Victoria Freitag Associate

San Francisco

Victoria serves as bond counsel and disclosure counsel on a variety of public finance transactions, including general obligation financings, conduit bond financings, sales tax revenue financings, and lease revenue financings for public agencies. Her practice spans across industries, with a particular focus on local government and affordable housing financings.

In collaboration with Orrick's Strategic Advisory & Government Enforcement group, Victoria advises financial institutions and community development practitioners on Community Reinvestment Act and fair lending matters.

Before practicing law, Victoria worked in outreach and operations for Mercy Corps' Community Investment Trust, an innovative communal ownership model designed to help local residents of all income levels invest in commercial real estate.

Warren Traiger Senior Counsel, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

New York

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D:+1 212 600 2375
E: [email protected]

Practice:

Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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Warren Traiger Senior Counsel

New York

He argued before the U.S. Court of Appeals for the Second Circuit in Lee v. Board of Governors, a benchmark case regarding the rights of community organizations to challenge Federal Reserve Board (FRB) determinations on merger applications. He has testified before Congress and the federal banking agencies on fair lending and CRA reform, served as Special Counsel to the New York banking regulator on CRA, and advised the regulator on predatory lending regulation.

Warren regularly helps banks and bank holding companies prepare the community convenience and needs portion of their regulatory applications to merge or acquire, and he helps clients respond to public comment regarding CRA and fair lending compliance. He represented a bank in its acquisition and integration of the finance arm of major automaker, directing pre-acquisition fair lending due diligence and updating the combined entity’s policies, procedures and regulatory relations strategy. Warren also served as an independent consultant for the New York Attorney General, overseeing compliance with that office’s settlement with a company that provides criminal background checks on prospective employees.

A prolific writer and researcher, Warren’s research and statistical analysis of mortgage lending data has been cited in publications of the Federal Reserve Banks of San Francisco, Boston and Dallas; the Federal Deposit Insurance Corporation (FDIC); and in testimony before the U.S. House Financial Services Committee.

Prior to joining Orrick, Warren was senior counsel at Buckley LLP. He also served as Co-Chairman of Traiger & Hinckley LLP. Prior to entering private practice in 1990, Warren was vice president, counsel and director of government relations for the New York Bankers Association, the trade group for New York commercial banks. He also served as director of legislation and research and special counsel for the New York City Department of Consumer Affairs and as a New York State Consumer Protection Board official.

Warren is entrenched in the New York legal and financial services community. He has served on the Banking Law Committee of the New York State Bar Association, as a member of the Banking Law and Consumer Law Committees of the Association of the Bar of the City of New York, and has taught as adjunct professor of economics at Hunter College of the City University of New York.