GeoDataVision

GeoDataVision

Is Fair Lending Enforcement Fair Today? Part II

Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is called a “REMA” or Reasonably Expected Market Area that can be unreasonably expansive…

 “Manufactured” Redlining

In a recent article in National Mortgage Professional entitled “Manufacturing Fair Lending”, former chief of the Housing and Civil Enforcement Section at the Department of Justice under Attorney General William Barr, Paul Hancock exposes the misuse of statistical analysis by…

Is Fair Lending Enforcement Fair Today?

Every banker should know by now that the Department of Justice announced an “Anti-Redlining” crusade in October 2021. In his October 2021, press release, Attorney General Merrick Garland, proclaimed that redlining is “pervasive” today and the DOJ will be working…

New CRA Retail Lending Test Benchmarks

The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many bankers, although not familiar with the specifics, have serious anxiety about the new…