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    CRA Interpretations

    As part of its responsibility for supervising and regulating the CRA activities of national banks, the Office of the Comptroller of the Currency, from time to time, issues letters interpreting the Community Reinvestment Act. Those letters are published in the monthly compilation Interpretations and Actions, and are available to read and/or download by selecting from the list below. Each letter is available in HTML by clicking on the letter number, in WordPerfect 6.1 for Windows format by clicking on the WP following the description, or in Microsoft Word 97 format by clicking on the WORD following the description.

    About the Presentation

    The letters have been redacted to remove business and other information that should be kept confidential, often including the names of the inquirer. Such redactions are indicated by brackets ([ ]). Similarly, letters in HTML format incorporate footnotes into the text. Those incorporations are indicated by a smaller type size and <NOTE: before the footnote text and > after it.

    About the Content

    These letters reflect the views of the Comptroller's legal staff and are subject to change.

    Letters Available

    Letter No.

    820 January 27, 1998 Letter states that financial institutions should collect and report (if required), the gross annual revenue or income of a small business or consumer borrower, rather than the adjusted gross annual revenue or income of the borrower. WP
    810 December 12, 1997 Letter states that financial institutions may receive favorable CRA credit for investing in a middle income housing down-payment assistance program if the investment is a "qualified investment" under the CRA regulation. WP
    809 November 20, 1997 Letter provides guidance about data collection requirements and performance standards for small wholesale institutions under the Community Reinvestment Act (CRA) regulations. WP
    802 September 17, 1997 Letter states that a financial institution's activities in connection with a program offering a financial services education curriculum for high school students would receive favorable CRA consideration if the students participating in the course were low- and moderate- income. WP
    800 September 11, 1997 Interagency CRA interpretive letter addressing three issues in connection with financial institutions' investments in pooled national community development funds. WP
    799 September 3, 1997 Letter provides broad applicable guidance pertaining to the treatment under the CRA regulations of financial institutions' participation in funds, such as the one described, which would invest in certain businesses. WP
    798 September 3, 1997 Letter states that if an unrated security is held, accounted for, and reported for CRA purposes by a financial institution as a loan or loan participation, the institution may have it considered under the CRA regulations' lending test. WP
    797 September 2, 1997 Letter provides broadly applicable guidance about how examiners would evaluate a financial institution's investment in notes of a fund established to improve business and commercial opportunity for economically disadvantaged individuals or business. WP
    795 August 14, 1997 Letter discusses whether examiners would favorably consider under CRA the activities of two community development corporations that the bank intends to form. WP
    794 (REV) August 11, 1997 Interagency CRA letter stating that an investment in an MBS bond that is specifically tailored to an institution's CRA requirements appears to be a "qualified investment" under the CRA regulations. [footnote # 2 has been revised.] WP
    793 August 5, 1997 Letter discusses how an examiner would determine whether loans for renovation of a housing project would receive favorable consideration under the CRA regulations. WP
    792 July 25, 1997 Letter discusses whether an institution that invests in an entity that supports small businesses in the institutions's assessment area receive positive consideration for making a "qualified investment" under the CRA regulations. WP
    787 June 10, 1997 clarification of "qualified investment" under the CRA regulations.WP
    784 May 30, 1997 treatment of equity-equivalent investments under the lending test. WP
    783 May 22, 1997 CRA consideration for contributions to the small business loan fund and contributions to the loan fund's operating expenses. WP
    775 November 4, 1996 CRA consideration for participation in community service programs offered by a financial company. WP
    774 October 2, 1996 CRA treatment of mortgage loans to fund part of a program to provide affordable housing. WP
    773 March 14, 1997 CRA status of a program to provide loans and financial management training to low-income parents. WP
    765 December 24, 1996 Loans for church premises that qualify as small business or community development loans. WP
    764 December 23, 1996 purchases of obligations of certain special purpose vehicles backed by affordable housing mortgages. WP
    763 December 23, 1996 investment in umbrella partnership real estate investment trust to engage in community development activities. WP
    762 December 11, 1996 CRA regulations and certain trade financing services. WP
    750 September 23, 1996 investment in a housing referral and assistance organization for low- and moderate-income individuals. WP
    746 September 9, 1996 participation in a revolving loan program (RLP) WP
    729 June 14, 1996 collecting and reporting locations of loans to borowers with non-geographic addresses WP
    728 June 18, 1996 treatment of the FMA "Direct Deposit Too" program WP
    727 June 26, 1996 treatment of "equity equivalent" instruments offered by a non-profit lender WP
    726 June 21, 1996 application of CRA regulations to support of microenterprise lending programs. WP
    723 April 15, 1996 purchase of debentures of a specialized small business investment company WP
    715 April 2, 1996 investment in a fund supporting affordable housing, education, & small business WP
    714 March 25, 1996 investments in CDBs WP
    713 March 4, 1996 student loans and the CRA WP
    710 February 21, 1996 lending by an affiliate WP
    709(Rev) June 14, 1996 investment in a community development bank (replaces 709)WP
    708 February 16, 1996 loans to a fund that provides mortgage insurance for affordable housing WP
    702 February 13, 1996 investment in a UIT holding mortgage securitiesWP
    701 January 31, 1996 grants to a clinic providing free health care for low-income patientsWP
    673 June 26, 1995 investments in a bank with a community development focus WP
    672 June 29, 1995 investments in a company that finances affordable housing WP
    665 May 31, 1995 grants to a non-profit educational foundation WP

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