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,…
Today, March 28, the regulators announced what many have been anticipating. The Agencies issued a press release indicating they intend to rescind the 2023 CRA rule. This is a good thing because the 2023 CRA rule was filled with some…
Earlier today, as I was writing this article the news broke about the regulators deciding they intend to rescind the 2023 CRA rule. My first reaction was to toss this article in the “trash” folder. But upon further reflection I…
Dear Banker, Many bankers are easily confused by the technical requirements for loans in “disaster areas” to be potentially qualified for community development credit under CRA. This brief article explains how to avoid the confusion. Numerous natural weather events have…
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is…
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The new size categories…
SamplesHMDA Market Data 2023CRA Market Data 2022Tract Income Class Map 2024Tract Minority Status Map 2024MSA Map 2024 SamplesNational Community Development Report – By StateNational CRA Small Business Market Report – By CountyNational HMDA Mortgage Market Report – By CountyNew CRA…
Dear Banker, On December 19, 2024 the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The new size categories will apply for the year…
No sooner had President elect Trump’s win been announced that speculation began about the implications for bank regulations. “Trump Administration may upend banking industry,” proclaimed a headline in USA Today, while Yahoo News ran a story titled, “Regulation Slowdown Expected…
During the last 15 years there have been notable changes in regulatory enforcement of potential redlining situations. This article addresses those changes. Originally, redlining prosecutions were limited to situations in which the lender’s intent to avoid or otherwise restrict access…
Performance Ratings Indicate They Already Have When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA…
Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule. But perhaps their frustration should be focused on the regulators who have promulgated the new rule which exempts…
Readers of this article may think I am referring to Orcas, sometimes known as “killer whales.” But what I am referring to is the new form of Assessment Area in the 2023 CRA Rule. However, the analogy/metaphor may be appropriate…
I’ve written articles critical of the Section 1071 Rule and the CFPB’s implementation of the new rule. For example, the scheduled “applicable dates” for data recording and reporting make no sense at all. As currently scheduled the applicable dates which…
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…