We know that loans will be reportable for both CRA and 1071. What if we collect DemographicInformation and the loan ends up being reportable for CRA? Being reportable for CRA does notdisqualify a covered transaction from being reported under 1071.…
It is important for you to be aware that the term “small business,” as outlined in Section 1071, specifically refers to the Small Business Administration (SBA) Regulations Part 121. In order to comply with the Section 1071 and to better…
Presented by GeoDataVision in partnership with M&M Consulting Brace yourselves! On March 30th, the CFPB unleashed the long-awaited Dodd-Frank Section 1071 Rule, and it’s about to shake the finance world to its core. Thought the CRA data file was a…
On February 13, the ABA Banking Journal bore a headline, “Nichols: ABA won’t ‘sit idly by’, if regulators overstep their authority”. The article went on to cite examples of rule making and regulatory changes “that will do more harm than…
We all know that Climate-Related Risk regulations are in the process. The prudential bank regulators are not waiting for lawmakers to legislate climate risk law, they are actively drafting “guidance” and will be evaluating climate risk exposure as a “Safety…
In emails in recent months we’ve warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ. The word is the DOJ…
One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is “Community Development Lending”. But while Community Development Lending is critically important, there is very little information available about the Community Development Loan Market. GeoDataVision has captured…
Dear Banker, Last year we learned that the Department of Justice Attorney General, Meritt Garland, announced an aggressive “Combatting Redlining Initiative.” At GeoDataVision we’ve observed the impact of this action on a growing number of community banks. However, what came…
Beware the Dramatic Implications for every bank! The effect of the switch-over from the census tracts for 2021 (based on the 2010 Census) and the 2022 tracts (based on the 2020 Census) cannot be overstated. Not only was there a…
Since the beginning of 2022, we’ve noticed an increasing number of community banks being pressured to expand their Assessment Areas and to annex nearby urban areas. There have been too many examples that we have seen for this to simply be…
Dear Banker, If the 2022 CRA NPR has you confused think again. Congresswoman Maxine Waters has just proposed legislation that makes the situation all the more confusing. Ms. Waters has just introduced a bill that would change the definition of…
One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is “Community Development Lending”. But while Community Development Lending is critically important, there is very little information available about the Community Development Loan Market. GeoDataVision has captured…
GeoDataVision is pleased to announce the availability of free interactive Metropolitan Statistical Area Maps on the Internet. MSA’s are a very important factor in Assessment Area delineation for CRA purposes. The map can be used to pan across and zoom into any area within the United…
The Trident Mortgage redlining fine should be a reminder to compliance risk management officers about the Fair Lending pitfalls a lender can fall into. It is clear that the DOJ and the “Bureau” have marching orders that differ from that…
There are some signs that regulators are becoming aware of the major problems inherent in the 2022 CRA NPR and are starting to question the cost and benefits of the proposed Rule. In an August 6, speech before the Kansas Bankers…
The controversial 2022 CRA NPR comment period ended on Friday, August 5. While the proposed Rule does have some very good improvements in the Regulation, it also had some very serious, if not fatal, flaws. The NPR was long (679…
Dear Banker,As I write this email there are fewer than 30 days to go before the comment period ends on the proposed CRA Rule that, based on data in the NPR, would increase the CRA exam failure rate by more than…
Dear Banker, Everyone has been inquiring about the new 2022 census tracts and their income classifications. The FFIEC as of this date (June 29, 2022) has yet to post the 2022 tract income classes on its geocoding website (although it…
As I continue to review the 2022 CRA NPR I am recognizing more and more potential problems for bankers if the Rule is adopted as proposed. Today I am going to briefly comment on what I call the “Double Whammy” for banks subject to the new proposed Retail Lending Test. What…
Register for the webinar Dear Banker, Readers and reviewers of the 2022 joint CRA NPR issued by the bank regulators on May 5 may be overwhelmed by the long (679 pages) and complex proposed rule-making document. Just trying to grasp…