OCC 2001-39
OCC Bulletin
Subject: Community Reinvestment Act
Description: 2001 Interagency Questions and Answers
Date: July 30, 2001

TO:  Chief Executive Officers and Compliance Officers of 
     All National Banks, Department and Division Heads, 
     All Examining Personnel, and Other Interested 
     Parties

On July 12, 2001, the bank and thrift regulatory members 
of the Federal Financial Institutions Examination Council
(Office of the Comptroller of the Currency, the Board of 
Governors of the Federal Reserve System, the Federal 
Deposit Insurance Corporation, and the Office of Thrift 
Supervision) (the agencies) published in the Federal 
Register an update of "Interagency Questions and Answers 
Regarding Community Reinvestment" (2001 Interagency 
Questions and Answers), which is a comprehensive 
interpretation of the Community Reinvestment Act (CRA) 
regulations.  The agencies consider the Interagency 
Questions and Answers to be the primary vehicle for 
disseminating guidance interpreting the CRA regulations.  
This update supersedes all previously published 
Interagency Questions and Answers.

The 2001 Interagency Questions and Answers adopt the 
revisions to one question and answer proposed in the 
April 28, 2000 version, along with a conforming amendment
to another question and answer.  Within the 2001 
Interagency Questions and Answers, we are also adopting 
six new questions and answers and making slight 
clarifying revisions to eight existing questions and 
answers.  

The 2001 Interagency Questions and Answers adopt the 
following revisions to previously proposed questions and 
answers that:

1. Explain that, if, in light of an institution's 
   performance context, an institution has adequately 
   addressed the community development needs of its 
   assessment areas(s), examiners will consider community 
   development activities that benefit low- and moderate-
   income individuals or geographies in the broader state
   wide or regional area that includes the institution's 
   assessment area(s), even if those activities do not 
   have a purpose, mandate, or function of benefiting the
   institution's assessment areas(s) - see §§ __.12(i) & 
   563e.12(h) - 5.

2. Clarify the definition of a "regional area" - see 
   §§ __.12(i) & 563e.12(h) - 6. 

In addition, the 2001 Interagency Questions and Answers 
adopt six new questions and answers that:

1. Provide guidance about the types of activities that 
   are considered to revitalize and/or stabilize low- and
   moderate-income areas - see §§ __.12(h)(4) & 563e.12
   (g)(4) - 1.

2. Clarify that certain lending activities may be 
   considered to be responsive to the credit needs of an 
   institution's assessment area - see §§ __.22(a) - 1.

3. Provide guidance regarding consideration for community
   development services performed by affiliates or third 
   parties on an institution's behalf - see 
   § __.24(e) - 1.

4. Provide guidance to CEBA credit card banks designated 
   as limited purpose that explains how they can help 
   meet their community's credit needs without losing 
   their exemption from the definition of "bank" - see 
   § __.25(a) - 1.

5. Discuss what is meant by "discriminatory or other 
   illegal credit practices" and provide examples of 
   "other illegal credit practices" that are inconsistent
   with helping to meet community credit needs. -  see 
   § __.28(c) - 1.

6. Provide guidance regarding maintaining public file 
   information on an intranet or the Internet - see 
   § __.43(c) - 2.

Interested parties are encouraged to review the attached 
2001 Interagency Questions and Answers.  For more 
information, contact Karen Tucker, national bank 
examiner, Community and Consumer Policy division, 
(202) 874-4446, or Margaret Hesse, special counsel, 
Community and Consumer Law division, (202) 874-5750.


_____________________________
Ralph E. Sharpe
Deputy Comptroller
Community and Consumer Policy



Attachment - 66 FR 36620