Could Lack of Impact Assessment in OCC and FDIC Proposal Break CRA?
A cardinal rule of any rulemaking is that a federal agency must use data and analysis to assess the impact of its proposed changes to a regulation. Based on NCRC’s analysis so far, it appears that the OCC and FDIC have flagrantly violated this fundamental rule.
Could Lack of Impact Assessment in OCC and FDIC Proposal Break CRA? Read More »