By David Freeman, Christopher Allen, Michael Mancusi and Anthony Raglani ( September 7, 2018, 1:06 PM EDT) -- On Aug. 29, 2018, the Office of the Comptroller of the Currency published an advanced notice of proposed rulemaking regarding reform of the regulatory framework implementing the Community Reinvestment Act of 1977.[1] Although the CRA and its implementing regulations have been updated on more than one occasion since the law's enactment, the regulatory requirements and performance expectations of the CRA regulatory framework are viewed by many industry participants as outdated and ineffective in achieving the objectives of the law. The OCC has now taken the first agency action toward modernizing this framework by soliciting public input on the ways in which the existing regulations can be revised to create greater clarity around banks' CRA performance expectations and to encourage banks to increase their lending and community development investment activities in low- and moderate-income (LMI) and other traditionally underserved communities....