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…
As any bank professional regulatory compliance professional knows redlining is the hottest issue today and has been since Attorney General Merrick Garland announced the “Combatting Redlining Initiative” in October 2021. Since then, the AG’s office has announced a record number…
When the Supreme Court decided in favor of the plaintiff in Loper Bright Enterprises et al vs. Gina Raimondo it overruled its decision in Chevron v. Natural Resources Defense Council, the so-called “Chevron Decision” which has been in effect for…
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…
The recent Supreme Court ruling that upheld the constitutionality of the Consumer Financial Protection Bureau’s funding resulted in the Bureau announcing the new effective dates for banks to begin collecting their CRA reportable data under the provisions of Section 1071…
Since October 2021, the prudential bank regulators in concert with the Department of Justice have been pursuing the “Anti-Redlining Initiative” announced by Attorney General Merrick Garland on October 21, 2021. During that time, I’ve been engaged by various banks to…
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…
Now that a Texas court has issued a temporary injunction delaying the April 1, 2024, scheduled implementation of the new CRA Rule should bankers relax and assume that the new rule’s effective date has been delayed for at least another…