WASHINGTON – Regulators in the Biden administration should largely to abandon last years very criticized the Office of the Comptroller of the Currency rule modernizing the Community Reinvestment Act and effectively recommencing CRA reform.

But even though regulators such as the Federal Reserve have identified aspects of the OCC’s approach that they oppose, the rule also contained several non-controversial measures with broad support that could help serve as a basis for a joint ARC framework supported by all bank branches.

Community groups and their allies in Congress objected to how ARC’s investments in low to moderate income communities across the country would be noted and encouraged under the ARC rule. For their part, banks opposed substantial new data and record-keeping requirements that would be used to make the OCC framework work and urged agencies to harmonize their different approaches.

Since September, policy analysts have largely turned their attention to the Fed’s CRA reform plans after the central bank issued a regulatory proposal notice describing a alternative approach. But the Fed’s plan is also somewhat complementary to what the OCC has finalized.

Before the Fed issues a more formal proposal, regulators must sort through around 600 public comments on the ANPR. While the general reception of the Fed’s plan seems warmer than reactions to the OCC rule, many commentators have pointed out some notable elements of the OCC approach that they wish to see preserved in a new rule-making process. .

Here are six characteristics that many, if not all, stakeholders want to see in a final agency-approved CRA regulation.