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Chevron is History. Implications for the 2023 Community Reinvestment Act regulations

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 more than 40 years and has deferred authority to federal bureaucrats regarding a federal agency’s […]

“Manufactured” Redlining

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 DOJ in concert with the federal bank regulators to concoct redlining allegations against mortgage […]

Should the CFPB Reconsider the Implementation dates for Section 1071 data collection?

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 of Dodd Frank. The new dates, which have been extended by 290 days as prescribed […]

Are Regulators Fairly Evaluating the Hottest Fair Lending Issue: Redlining?

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 help them respond to threats by regulators to refer them to the DOJ for alleged […]

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 with the prudential bank regulators and state attorneys general as “force multipliers” in a new […]

Will the Regulators Implement a Key CRA Rule Component by Stealth?

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 year at the earliest? Maybe, but maybe not! A key goal of the new rule […]

Adapting to Change: Navigating the New CRA Regulations and Planning Regions in Connecticut

This webinar, presented by Len Suzio, focused on the new Community Reinvestment Act (CRA) regulations and their implications, especially considering the introduction of new planning regions in Connecticut. The key points of the webinar included: Overall, the webinar served as a comprehensive guide to understand the upcoming changes in the CRA and their specific impacts […]

Postponement of April 1, 2024 “Applicable” Date May Cause More Confusion

The March 21, 2024, announcement that the prudential bank regulators have decided to postpone the scheduled April 1, “applicable” date for the Facility-based assessment areas, the new Public File section and the Public Notice Section provides some welcomed relief to bankers who have been inundated with a Tsunami of new or revised regulations in the […]

The Answers to the CRA Questions Everyone is asking: What must we do on April 1?

With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers. There are 3 sections of the new CRA that are banker’s responsibility and become effective on April 1, 2024. §_.16 Facility-based assessment areas §_.43 Content and […]

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 performance standards and with good reason. Much of the anxiety is understandable because in the […]

Assessment Areas under the new CRA rule – Estimated Standards to be available soon

There has been much understandable confusion about many aspects of the new CRA rule. But perhaps there’s been no greater confusion and anxiety than about the Assessment Areas. And this anxiety has become more acute the closer we get to April 1, 2024, the effective date for the new rule and the “applicable” date for […]

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 in CRA Assessment Area delineation. The FFIEC adopted the new MSAs effective January 1, 2024. […]

The Potentially Adverse Fair Lending Implications of the New CRA Rule

There has been much understandable handwringing about the new CRA and its complexity as well as the high CRA exam failure rate predicted by regulators based on the new assessment areas and the higher performance standards embedded in the new rule. But there is a greater potential regulatory threat that goes beyond the CRA performance […]

How to Figure Out How the New CRA Affects Your Bank

I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if the new rule had been in effect during 2018-2020 that failure rate could […]

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 the Court rules on the 1071 challenge which will be this June. I suggest speaking […]

The new CRA Rule: Confusion Reigns

Our office has been inundated with inquiries about an aspect of the impact of the impending new CRA rule. As we have noted in previous articles there are mistakes and inconsistencies in the new CRA Rule, and some of these mistakes and inconsistencies will have immediate consequences for about 200 US banks. What we are […]

What is a “REMA” and why is it so important?

As I write this article the Department of Justice is pursuing a record-breaking number of “redlining” cases against banks and mortgage lenders. The “Anti-redlining Initiative” was announced October 22, 2021, by Attorney General, Merrick Garland. In his press release AG Garland stated, “We know full well that redlining is not a problem from a bygone […]

Coming Soon: Climate Risk Assessments for Banks – Are You Ready?

Climate Risk Assessments for banking purposes are in the early stages of development. No laws or regulations have been issued regarding the topic. Nonetheless, it is obvious that lawmakers and regulators are keenly intent on developing laws and regulations to require banks to develop climate-related risk assessments. The Chairperson of the Federal Reserve and various […]

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