WASHINGTON - Regulators are still struggling to implement key components of the new community reinvestment rules.

In two documents quietly being circulated, the Federal Reserve and the Office of the Comptroller of the Currency are soliciting input on the best way to execute some of the most controversial aspects of the Community Reinvestment Act rules adopted in April.

Issues being debated include how to calculate loan-to-deposit ratios, how to compare similar banks, and how to define wholesale banks.

"What it suggests is the regulation provided just a bare-bones framework," said Steve Zeisel, senior counsel at the Consumer Bankers Association. "As we always suspected ... there are a lot of questions that remain unanswered."

Topping that list of unanswered questions is the loan-to-deposit ratio. Regulators encountered storms of protest when they previously proposed that any bank with a 60% ratio would get a satisfactory grade. So, they dropped the exact figure.

But the documents being circulated show that regulators still want a loan-to-deposit ratio from each bank. They propose averaging each quarter's ratio to produce the final figure. Also, they suggest awarding bonus points for community development lending.

The answers to these and the other questions will be incorporated into the guidelines that examiners are writing to provide more insight into the CRA rules. The instructions should be completed this fall so training can begin. New CRA exams for small banks begin Jan. 1, while banks with more than $250 million in assets will not receive the new exams until July 1997.

"The OCC thinks it is important to have input from a wide range of sources so we can formulate our exam procedures to carry out the intent of the law with maximum efficiency and minimal burden," said Konrad Alt, the Comptroller's chief of staff.

The Fed's staff refused to talk about the list of questions sent to banks, trade groups, and consumer advocates.

Regulators completed a massive overhaul of the reinvestment rules this spring, switching from a process-oriented system to one that focuses on lending, investment, and service.

The two documents also ask what indexes regulators can use to compare institutions, and whether they should compare out-of-market banks.

Jo Ann S. Barefoot, an industry consultant at Barefoot, Marrinan & Associates in Columbus, Ohio, said she doesn't believe any ideal indexes exist. But regulators must compare out-of-market banks because there are too few similar in-market institutions, she said.

Regulators also asked how they should determine what qualifies as a wholesale bank, and how much incidental lending a specialized bank can do and remain eligible for the streamlined exam.

Warren Traiger, a New York attorney who represents a coalition of these specialized banks, said regulators should simply evaluate whether the lending is truly incidental to the wholesale bank's main business. If it is, then the bank should qualify as a wholesale institution, he said.

Paul Allen Smith, senior federal counsel at the American Bankers Association, said some of the answers are obvious. For example, regulators asked how they should grade banks that operate in more than one service area. Banks should get pro rata credit to ensure the score reflects the bank's primary market, he said.

Also, he said regulators should know the answer to whether bankers should receive credit for using innovative CRA programs that other banks already have developed.

"If it is a reach by the institution, it ought to count," he said.

The agencies also asked whether they should award small banks "outstanding" ratings if they have top lending records but no service or investment in the community. And they asked whether different types of financing should carry more weight in the lending test.

Community activists declined to react to specific questions on the list. But they said they are encouraged that the regulators asked for input. "It is too early to say whether it is good news or bad news," said Allen Fishbein, general counsel to the Center for Community Change.

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