#2021-6, February 19, 2021

MBA Comments on Fed CRA Advanced Rulemaking Notice on CRA

Earlier this week, the Association submitted comments to the Federal Reserve in response to the central bank’s Advanced Notice of Proposed Rulemaking (ANPR) on updating its Community Reinvestment Act (CRA) regulations.  As we have reported previously, the Office of the Comptroller of the Currency (OCC) issued final CRA rules last year that did not include the Fed or the Federal Deposit Insurance Corporation (FDIC).

While MBA’s letter notes several areas of agreement outlined in the Fed ANPR, such as proposed changes to the definition of “large” and “small” institutions for CRA purposes and the clarification on CRA qualifying activities, we continue to raise our serious concerns with a regulatory and assessment structure that is not consistent among the agencies.  In particular, the letter notes that Massachusetts is unique in that we have our own state CRA statute and regulations and that the examination process for state-chartered banks would be more burdensome if the state and federal requirements are not standardized.

To read MBA’s letter, click here.

Federal Foreclosure Moratorium, Mortgage Forbearance Programs Extended Until June 30

President Biden announced this week that most federal foreclosure moratoriums and mortgage forbearance programs that were set to expire in March will be extended until June 30.  The programs apply to loans guaranteed by the Department of Veterans Affairs or Department of Agriculture, and those insured by the Department of Housing and Urban Development.

According to the announcement, the existing foreclosure moratorium for those homeowners will now be extended through June 30 and borrowers may also request forbearance until June 30.  Borrowers who entered forbearance before June 30, 2020, can now request two additional forbearance extensions in three-month increments.

To read more, click here.