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On May 20, 2020, the Office of the Comptroller of the Currency (OCC), which regulates national banks, released a Final Rule intended to strengthen and modernize the implementation of the Community Reinvestment Act, 12 U.S.C. § 2901 et seq. (the CRA). The CRA was originally enacted in 1977 to reverse decades of financial “redlining” whereby banks were not servicing the needs of all, particularly communities of color, by encouraging banks to help meet the credit needs of all local communities it serves, including low- and moderate-income (LMI) neighborhoods.1 The CRA requires federal banking agencies to assess a bank’s record of meeting the credit needs of its entire community, including LMI neighborhoods, consistent with the safe and sound operation of such institution, and take such record into account in its evaluation of an application for a deposit facility by such institution.

Read the full GT Alert, “OCC Final Rule Modernizing the Community Reinvestment Act Includes New Incentives for Investing in Indian Country.”


112 U.S.C. §2901 (“It is the purpose of this chapter to require each appropriate Federal financial supervisory agency to use its authority when examining financial institutions, to encourage such institutions to help meet the credit needs of the local communities in which they are chartered consistent with the safe and sound operation of such institutions.”).

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Heather Dawn Thompson

Heather Dawn Thompson focuses her practice on American Indian law, federal Indian policy and advocacy, tribal sovereignty, tribal economic development (including energy, finance, and telecom), community, sovereign economic development, and tribal nation building (including constitutions, codes, and courts). She works with individual tribes,

Heather Dawn Thompson focuses her practice on American Indian law, federal Indian policy and advocacy, tribal sovereignty, tribal economic development (including energy, finance, and telecom), community, sovereign economic development, and tribal nation building (including constitutions, codes, and courts). She works with individual tribes, tribal and Indian-owned businesses, and intertribal associations.

Prior to joining the firm, Heather was an Assistant U.S. Attorney for the U.S. Attorney’s Office in South Dakota’s Indian Country Section. There, she was an Indian Country Federal Prosecutor on the Pine Ridge Indian Reservation. Heather covered violent sex crimes and violence against women.

Heather is widely recognized for her work while serving as the Director of Government Affairs for the National Congress of American Indians (NCAI), the nation’s oldest and largest inter-tribal organization.

Heather is the Past President of both the South Dakota Indian Country Bar Association and the National Native American Bar Association. Heather is an enrolled member of the Cheyenne River Sioux Tribe.

Photo of Jennifer D. Newton Jennifer D. Newton

Jennifer D. Newton, a former federal financial services regulator, advises banking and financial institutions on risk management and compliance matters relating to federal and state consumer protection laws and regulations. Additionally, Jennifer works with a variety of clients on privacy and financial technology…

Jennifer D. Newton, a former federal financial services regulator, advises banking and financial institutions on risk management and compliance matters relating to federal and state consumer protection laws and regulations. Additionally, Jennifer works with a variety of clients on privacy and financial technology (fintech) matters involving data security, data breach, open banking, and payment system issues under the Global Data Privacy Regulation (GDPR), the Electronic Funds Transfer Act (EFTA), and federal and state privacy laws, including the California Consumer Privacy Act (CCPA), Gramm Leach Bliley Act (GLBA), Computer Fraud and Abuse Act (CFAA), Health Insurance Portability and Accountability Act (HIPAA), Americans with Disabilities Act (ADA), Fair Credit Reporting Act (FCRA), and the Florida Information Protection Act (FIPA).