If you are worried about “redlining” you’d better understand statistical significance The perennial question facing all banks is, “What volume of lending in Majority-Minority census tracts and mortgages extended to minority home borrowers must we do to avoid redlining allegations…
The FFIEC released the official 2024 HMDA Aggregate & Disclosure file in June. GeoDataVision uses that data to create special market rank and market share reports for markets everywhere in the USA. This data is invaluable for CRA and Fair…
Dear Senators, I have been a consultant regarding the Community Reinvestment Act since 1994 and have advised hundreds of banks and occasionally a community group about an institution’s CRA responsibilities. I am one of the few people in the country…
If they did here’s one way to handle it Under the Biden Administration the prudential bank regulators and the Department of Justice initiated a program of aggressive enforcement against redlining by lenders of all types. Announced by Attorney General Merrick…
Regulatory Compliance has been an ever-evolving process for decades. But at least the changes have been mostly steady and slow. But during the last 15 years the pace of regulatory change has not only accelerated, but it’s also become a…
There’s a very big inconsistency in the Community Reinvestment Act. The current CRA rule was passed in 1995 and requires every FDIC insured bank to meet the credit needs of the communities they serve. All “covered” banks are subject to…
A milestone discussion on the past, present, and future of the Community Reinvestment Act A Historic Milestone Meets a Historic Expert For our landmark 100th episode of the Compliance 9-1-1 Show, hosts Dean Stockford of M&M Consulting and Len Susio…
The Trump Administration officially has announced it intends to emphasize “deregulation” with a focus of eliminating 10 regulations for every new regulation. Eliminating regulations is one thing, but enforcement is another matter. Roy Cohn, who advised Trump early in his…
Bank regulators have announced their intention to repeal the 2023 CRA Rule. But it would be a mistake to stop there. For more than a decade there’s been a clamoring to “modernize” the CRA regulations. If the Administration should merely…
On June 18, 2025, the CFPB published its 2025 Section 1071 Interim Final Rule. Lenders covered by the 2024 Section 1071 Interim Final Rule should know what the 2025 Rule is changing, how it affects them and what they can…
Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public domain and is transparent…
Now that the Trump Administration has announced its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule. It was unbelievably complex, confusing and intimidating, and it excluded…
Banks play a pivotal role in the economic wellbeing of our nation and local communities. Banks do this by being “financial intermediaries” facilitating the flow of funds between savers and borrowers. This obligation is so important that Congress passed legislation…
President Trump signed Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy on April 23, 2025”. The EO proclaims a policy goal of eliminating “the use of disparate-impact liability in all contexts to the maximum degree possible’”. Given the relatively…
Just when you thought the flurry of executive orders pertaining to “deregulation” might have slowed down, the President signed, on April 23, 2025, Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy.” The EO proclaims a policy goal of eliminating…
In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I…
In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice…
In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule: 1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment areas mandated in the 2023 rule…
Fill in your details to watch now. In this webinar, we will take an in-depth look at why the 2023 CRA Rule is detrimental to all communities, including underserved areas. Rather than improving the CRA, the rule introduced serious flaws…
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices,…