guidelines for the revised Community Reinvestment Act rules by Nov. 13, about four months behind schedule. The guidelines are expected to resolve scores of questions about how the new CRA rules - which begin phasing on Jan. 1 - will work. But even if the regulators make the new deadline, industry officials said bankers may have trouble adjusting their CRA programs by yearend. Learning in mid-November how examiners will evaluate banks under the new rules leaves only a few weeks at the height of the holiday season to modify systems and train employees. "This is problematic," said Paul A. Schosberg, president of America's Community Bankers. "You are throwing up enormous obstacles for prompt and accurate compliance." Mr. Schosberg said regulators may have to delay the Jan. 1 implementation date. Several bankers echoed that sentiment. "Given all that is riding on this, we shouldn't mess with it and force a date of Jan. 1 when a date of July 1 might make more sense," said Catherine Bessant, a senior vice president at NationsBank Corp. "Let's not lose the forest for the trees." But in interviews this week, regulators from all four agencies said that postponement is out of the question. "There is no support to delay implementation past Jan. 1," said Jonathan L. Fiechter, acting director of the Office of Thrift Supervision. In addition, the regulators are making progress. Banks have already received some of the technical specifications for new data reporting requirements, and agency officials claim they are wrapping up the few remaining details on the instructions for examiners. Mr. Fiechter said Nov. 13 is the target date because that's the day the agencies conduct a regional training session for examiners in San Francisco. "We would like to finalize them prior to Nov. 13," Mr. Fiechter said. "I believe that is possible." The agencies also plan to provide free software in mid-December to help banks comply with the data collection requirements, Comptroller of the Currency Eugene A. Ludwig said. "I am confident this is being done in a timely fashion, and that everybody will be able to comply," Mr. Ludwig said. Regulators revised the CRA rules in April, replacing a process-oriented system with one that measures performance. Several chunks of the new rules take effect Jan. 1, including streamlined tests for banks with less than $250 million in assets and specialized exams for wholesale and limited- purpose institutions. Large banks also must start collecting the race and gender of small-business borrowers. Details of the instructions to examiners have leaked out, and the large- bank guidelines drew quick condemnation from the industry. The biggest complaint is that examiners will rate a bank on how well it ascertains the community's credit needs rather than on its actual lending. Mr. Ludwig himself bashed the small-bank exams, telling the American Bankers Association's annual convention last month that regulators "trashed" the most burdensome of those rules. But the Federal Reserve did not agree with the Comptroller's attempts to simplify the small bank CRA exam. In an Oct. 27 memorandum to Fed Governor Lawrence B. Lindsey, Glenn E. Loney, an associate director in the central bank's division of consumer and community affairs, called the Comptroller's revisions "confusing," "condescending to examiners," and "inconsistent with the regulation." Mr. Loney criticized the Comptroller's office for trying to micromanage examiners in the field. In particular, Mr. Loney flagged several instances where Mr. Ludwig wanted to change the guidelines to specifically prevent examiners from reviewing a bank's customer service area unless a consumer had filed a complaint. Mr. Loney accused the Comptroller's office of producing a document that is confusing and ineffective. Government officials said regulators resolved this dispute Wednesday by agreeing to drop the Comptroller's changes. While regulators bicker over various sections of the guidelines, bankers are worried about complying with scores of changes. The data collection requirements raise some of the thorniest issues. Karen Alnes, who directs Minneapolis-based Norwest Corp.'s CRA programs, said bankers cannot reprogram their computers until they receive the technical assistance the agencies have promised. That's en route. Regulators began mailing the technical specifications to large banks on Oct. 27, according to Stephen Cross, deputy comptroller for compliance management. Bankers hoping to take advantage of the strategic plan option - which allows an institution to design its own CRA requirements - also are complaining that they won't be able to decide on Jan. 1 whether to apply. "A lot of institutions are waiting for more information before deciding if they are going to take the time and effort to draw up their own plan," said Sidney J. Miller, senior vice president at Pacific Southwest Bank in Dallas. "You would be hard pressed to make that business decision until you get all the rules in place." Bankers also said they are not sure how to geocode rural loans, how to include consumer loans in the lending test, and how to handle community development lending conducted through a nonprofit neighborhood organization. Mr. Ludwig said he understands the industry's need for more guidance, but won't release the guidelines until he is convinced they are as free of unnecessary burden as possible. While bankers concede that the new rules will eliminate several paperwork requirements, they said they don't expect any material reduction in time or money spent on compliance. "Overall, the changes will not lower our CRA regulatory burden," said Douglas Woodruff, president of Boatmen's Community Development Corp. in St. Louis. "For most institutions, it will probably increase it."

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