Category Uncategorised

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…

Changes to 2024 MSAs Have Implications for CRA

In July 2023, the Office of Management & Budget published an update to “Core Based Statistical Areas, Metropolitan Divisions, and Combined Statistical Areas”. That document contains the latest definitions of Metropolitan Statistical Areas or “MSAs’) which play a big role…

2024 CRA Q&A

 How will loan data collection change given the pause on the 1071 rule? If that’s not a topic for today, where can I find a good source for information regarding loan data collection? I would not make any changes until…

2022 Community Development Report by State

2022 CRA data released by the FFIEC December 2023 Ordered Alphabetically by State 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…