On March 23, 2021, the Illinois Community Reinvestment Act (“IL CRA”) was signed into law. The stated purpose of the IL CRA is to ensure that covered financial institutions are equitably providing financial services across the state, including to low- and moderate-income neighborhoods, and areas where there is a lack of access to safe and affordable banking and lending services. Since that time, the Illinois Department of Financial and Professional Regulation (the “IDFPR”) has been working to finalize the IL CRA’s implementing regulations.
Continue Reading Watching-and-Waiting: The Illinois Community Reinvestment Act
On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors of the Federal Reserve System (“FRB”) (the OCC, FRB and FDIC are collectively, the “Federal Banking Agencies”) issued revisions to the Interagency Biographical and Financial Report (the “Report”).
According to the Federal Deposit Insurance Corporation (“FDIC”), from 2000 to 2008 there were 1,042 de novo community banks newly chartered in the United States. From 2011-2017, the FDIC received only 30 de novo applications for deposit insurance. Of those 30 applications received, six have been approved, 10 withdrawn and 14 remain outstanding. At year end 2017, the number of U.S. banks fell below 5,700 – a number the industry hasn’t seen since the 19th century. Recently, the FDIC indicated that it has warmed to the idea of accepting de novo bank applications. Now may be the time for interested investors to assess the possibility of entering the community bank industry.