|On May 20, 2020, the Office of the Comptroller of the Currency (OCC) released a final version of revised rules for the Community Reinvestment Act (CRA) that define, for the banks they regulate, obligations to meet the economic, credit and service needs of low- and moderate-income (LMI) people and neighborhoods in which they are located. The final regulations represent a historic change by providing clear guidance and examples of qualified CRA activities that will address the multiple ways investment, lending and services can support the unmet needs of low- and moderate-income people with disabilities.
Under these new regulation changes, for the first time, LMI individuals with disabilities are specifically identified as an eligible group that represents a subset of the LMI community in a bank’s service areas.
In response to comments led by National Disability Institute (NDI) and the Center for Disability-Inclusive Community Development (CDICD), and echoed by other disability groups and some financial institutions, the OCC states, for the first time in CRA rules, that “activities that benefit or serve LMI individuals with disabilities” will meet several qualifying activities criteria in the final rule.”
Last year, banks spent more than $440 billion meeting CRA obligations. This is an unparalleled opportunity for disability organizations and public agencies to engage in discussion with banks regulated by OCC to identify ways to work together to increase the funding level and types of CRA activities that will address the investment, lending and service needs of low- and moderate-income people with disabilities.