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News & Information
Potential Improvements for CRA (Part 4c of 4)
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 put forward another 3 potential improvements to the legacy rule. I suggest to the regulators […]
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Potential Improvements for CRA (Part 4b of 4)
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 of Proposed Rulemaking regarding the repeal of the 2023 CRA rule. Adopt a Simplified Version […]
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Potential Improvements for CRA (Part 4a of 4)
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 2. The elimination of some very important loan types in the Retail Lending Test thereby undermining […]
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The 2023 CRA Rule Repeal: Good Idea? Bad Idea?
Webinar Details:Date & Time: May 7, 2025 02:00 PM EDTCost: Free 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 that undermine its effectiveness as a tool for measuring how banks serve […]
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The 2023 CRA Needed to be Repealed and Replaced: The Confusing Ratings System (Part 3 of 4)
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, significantly fix the flaws or repeal the 2023 Rule altogether. To those alternatives I add […]
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Agencies announce intention to rescind 2023 CRA rule
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 very bad ideas, including unrealistic assessment areas, the omission of loans important to the community, […]
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Former Senator: Bankers Can’t be Passive about proposed CRA Rule Rollback
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 realized that the rescission hasn't been approved yet, and the Agencies will need to go […]
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Designated Disaster Areas and CRA Community Development: Be Careful!
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 caused FEMA to issue declarations for designated disaster areas. Certain bank activity in those areas […]
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The New Modern” Community Reinvestment Act Needs to be Fixed ASAP
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 scheduled to become “applicable” January 1, 2026. So, what are the problems that are so […]
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CRA Size Standards
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 apply for the year 2025. Really Important notice for small banks near the ISB size […]
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Agencies Announce New Size Thresholds and Clarification of Confusion about Size Standards
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 2025. Banks that qualify as Intermediate-small banks are immediately subject to ISB examination standards for […]
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Announcing: GeoDataVision CRA and Fair Lending Compliance Resource Center
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 Demographic Benchmark Report- By State & CountyNew CRA HMDA Benchmark Report- By State & CountyNew […]
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There’s a New Sheriff Coming to Town What are the Implications for CRA and Fair Lending?
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 under Trump Administration,” Not to be outdone, Bloomberg News ran a story about “Trump’s ‘Epic’ […]
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The Regulators Evolving Approach to Redlining Enforcement
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 to mortgage credit was demonstrable by specific cases. However, beginning with the Obama Administration in […]
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Have Regulators Already “Raised the Bar” for CRA Exams?
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 performance ratings are in it looks like the regulators may already have raised the bar! […]
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The new Community Reinvestment Act Omits Critical Types of Credit That Meet Community Needs
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 from CRA examination critical types of credit extended by banks to meet the needs of […]
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The Killer ORLA Concept in the new CRA Rule
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 because the concept of an ORLA, or “Outside Retail Lending Area”, is an absolute killer […]
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Section 1071 Rule: The Big Gap Between Small Business Lending and “Covered” Loans
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 mandate capture of 1071 data are July 18, 2025, for Tier 1 lenders, January 16, […]
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