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 pages) and complicated.
In fact, the proposed Rule was so complicated that even the regulators seemed not to understand the strange consequences of their proposed ideas.
A good example can be found in the application of the concept of “Major Product Line” which would subject only those retail product loans that constitute at least 15% of the dollar value of a bank’s lending in any market.
GeoDataVision studied the 2020 HMDA and CRA Aggregate & Disclosure data and identified more than 2,189 small business lenders ranked in the Top Ten small business lenders in their local counties that would be exempt from having their small business lending activity in those counties examined under CRA!
If you are interested in reading the last comment letter sent to the regulators by GeoDataVision including a list of the 2,189 small business “Top Ten” Lenders in 1,332 counties
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