ABA, state bankers associations offer recommendations for CRA rules revisions

The American Bankers Association and 45 state bankers associations said in a letter to the FDIC and the Office of the Comptroller of the Currency that the small bank threshold should be increased to $1 billion. The intermediate bank threshold should be increased to $10 billion, and both thresholds should be indexed to nominal GDP, the associations said.

The associations said they appreciated the proposal's renewed focus on credit needs and not deposit products.

The associations said the agencies should adopt a rule that provides clear and durable expectations, reducing the uncertainty and disruption associated with repeated rounds of regulatory change. They also said retail service evaluations should remain focused on credit.

Large banks should receive at least two years before becoming subject to new data collection and reporting requirements, the associations said. Banks that move to a different asset classification should have the option either to transition to the applicable framework on Jan. 1 of the following calendar year or to complete the current evaluation period under the existing rules, the associations said.