The OCC recently requested public comments on its Advanced Notice of Proposed Rulemaking (ANPR). Though issued solely by the OCC, the ANPR was widely interpreted as the first step in an Interagency effort to revise, update and modernize the regulations and guidance supporting the Community Reinvestment Act (CRA). Centrant’s position has been that CRA is overdue for an update, and that the regulatory agencies must provide greater regulatory guidance and clarity to banks concerning the eligibility of various CRA-related activities, particularly when those activities occur outside of an institution’s delineated CRA assessment areas. A copy of Centrant’s ANPR response letter is available here. We will continue to work closely with the North Carolina Bankers Association to monitor and assess any proposed changes to CRA.