Financial institutions are regulated on the national level by four regulators. These four regulators are the Federal Reserve, The Office of the Comptroller of the Currency, the Office of Thrift Supervision and the Federal Deposit Insurance Corporation.
The Federal Reserve System (FRB) supervises state-chartered banks that are members of the Federal Reserve System. The Federal Reserve also regulates bank holding companies and is thus the agency which provides key decisions in the largest bank mergers.
The Office of the Comptroller of the Currency (OCC) supervises national banks. Because of this the OCC examiners provide the CRA ratings for many of the largest banks. Thus while the Federal Reserve makes the crucial decisions in the merger application process, they usually cite the satisfactory CRA rating provided by the OCC as proof that the bank is meeting the credit needs of low and moderate income communities.
The Office of Thrift Supervision (OTS) supervised federally and state-chartered savings associations and savings banks. Because of a loophole in the law which allows non-banks the ability to obtain a unitary thrift charter, the OTS is in the middle of the current fight to extend community reinvestment type provisions to all financial companies.
The Federal Deposit Insurance Company (FDIC) supervises state-chartered banks that are not members of the Federal Reserve System and thus is usually only involved with the smaller banks.
With each of these agencies routine applications are usually handled at the regional level. The national offices usually become involved in more complicated applications or when an application has been challenged.
Only a few states have their own Community Reinvestment laws. Connecticut, Massachusetts, New York, Rhode Island, Washington, West Virginia, and the District of Columbia have such laws, so the bank regulators in those states should be amenable to your input on a bank's record of lending to the community. Occasionally the New York State Banking Commission has required additional lending efforts by the banks, but for the most part the state banking commissioners will not get out in front of the national bank regulators.
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