White Paper

3 Pages
  • 3 Pages

OCC Bulletin Allows CRA Downgrades for Evidence of Discriminatory Credit Practices


The Office of the Comptroller of the Currency releases Bulletin 2018-23.

This bulletin announces small, although important, changes to OCC policy concerning evidence of illegal or discriminatory credit practices contributing to a mark down of a national bank’s Community Reinvestment Act examination rating. This white paper reviews the bulletin and explains the circumstances that could condone a downgrade of two CRA rating levels.



Ronald K. Vaske

Ballard Spahr LLP

Ronald K. Vaske is an attorney with Lindquist & Vennum, PLLP. His practice is focused on financial institutions, particularly in the areas of commercial and consumer finance. He has represented banks and bank holding companies in connection with regulatory matters, mergers and acquisitions, and commercial transactions. In the commercial finance area, he has advised lenders and borrowers in traditional debt financing and structured finance transactions. These include: commercial loans, public and private debt offerings, asset securitizations through rated and nonrated offerings and commercial paper conduits. He earned his B.S. degree from South Dakota State University and his J.D. degree from Creighton University School of Law. He is admitted to the bar in Minnesota, South Dakota and Nebraska. Prior to entering the legal profession, Mr. Vaske worked in the banking industry for nine years. Mr. Vaske was recognized as a Rising Star in Minnesota Law 2003 (MSP Communications).

Jacob N. Westlund

Ballard Spahr LLP

Jacob Westlund assists banks, bank holding companies, and financial institutions with a range of matters, including transactions, commercial lending, bank lifecycle developments, regulatory requirements, and compliance issues. Jacob approaches his clients' needs with full awareness of the challenging regulatory environment in which financial institutions operate and the importance of efficient, reliable legal advice.

Prior to entering law, Jacob served at a large national bank where he was responsible for conducting a rigorous, enterprise-wide assessment of top compliance and risk issues. The assessment evaluated the effectiveness of senior leadership – including the board of directors, senior management, and top-level committees – as well as the bank’s governance, strategy setting, and overall risk management infrastructure.

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