OCC 2000-15 
Subject: Community Reinvestment Act
Description: 2000 Interagency Questions and Answers
Date: May 19, 2000


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


On April 28, 2000, the 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" (2000 Interagency 
Questions and Answers), which is a comprehensive interpretation 
of the Community Reinvestment Act (CRA).  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.

Among other issues, the 2000 Interagency Questions and Answers:

   o State that an institution may not receive investment 
     test consideration for a mortgage-backed security that 
     is primarily or exclusively backed by loans originated 
     or purchased by the same institution - see §____.23(b)-2 
     on page 25103;

   o Revise the reporting requirements for renewed and 
     refinanced small business and small farm loans, 
     beginning with data collected in 2001 and reported 
     in 2002.  As revised, an institution will report both 
     refinancings and renewals as originations, subject to 
     a one-origination-per-year limitation - see §____.42(a)-5 
     on page 25110;

   o Amend the instructions for the renewals of lines of credit 
     for small business, small farm, and consumer purposes, if 
     applicable, in the same manner as renewals of small business 
     or farm loans as discussed above, beginning with data 
     collected in 2001 and reported in 2002 - see §____.42-4 on 
     page 25109;

   o Clarify whose income should be reported by an institution 
     that makes a consumer loan to more than one borrower and 
     chooses to have consumer loans considered - see §____.42(c)
     (1)(iv)-4 on page 25113;

In addition, the document seeks additional comment on one question 
and answer that was proposed for comment in May 1999 and one 
conforming question and answer.  The proposed question and answer 
discusses whether there must be some immediate or direct benefit to an
institution's assessment area(s) to satisfy the regulation's 
requirement that qualified investments and community development 
loans or services benefit an institution's assessment area(s) or 
a broader statewide or regional area that includes the institution's 
assessment areas(s).  We have slightly revised the proposed 
question and answer to ensure that the public understands that 
the question and answer expands the current guidance, because 
it appeared that a number of commenters did not recognize the 
May 1999 proposal as an expansion of existing options for 
institutions to engage in community development activities 
outside their assessment area(s).  See comments beginning on 
page 25090 regarding §____.12(i)-5.

Discussion of the proposed conforming question and answer for 
§____.12(i)-6 can be found on page 25091.  This question and 
answer would be revised to be consistent with the changes to 
§____.12(i)-5 and would provide guidance to the examiners 
when evaluating a bank's performance under these expanded options.

We invite public comment on any of the new and revised questions 
and answers, as well as other community reinvestment issues that 
are not addressed in these 2000 Interagency Questions and Answers.  
We request that comments on the proposed questions and answers 
be submitted to Executive Secretary, FFIEC, 2000 K Street, NW, 
Suite 310, Washington, DC  20006, or by facsimile transmission 
to (202) 872-7501 on or before June 27, 2000.  The agencies 
intend to update the Interagency Questions and Answers periodically 
and may include questions received from the public in future guidance.

Interested parties are encouraged to review the attached 2000 
Interagency Questions and Answers.  For more information, contact 
Malloy Harris, national bank examiner, Community and Consumer 
Policy division, (202) 874-4428, or Margaret Hesse, senior 
attorney, Community and Consumer Law division, (202) 874-5750.



_____________________________
Ralph E. Sharpe
Deputy Comptroller
Community and Consumer Policy

Attachment - 65 FR 25088