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Section 1071 Q&A post two

It seems that a banker will need to determine if the loan they are taking an application for is a HMDA loan, a CRA loan or Section 1071 loan. It is possible that a loan will be reportable for CRA and not Section 1071. Is there any safe harbor if a banker thought it was […]

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Section 1071 Q&As post one

How can you report GAR as ‘not provided’ if you need to know this number in order to determine if it is reportable for Section 1071? It is my understanding that you do not have to verify GAR, so if a borrower tells you about $3M, then wouldn’t that be the amount to report instead […]

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Free Small Entity Compliance Guide

The document is a Small Entity Compliance Guide for the Consumer Financial Protection Bureau's Small Business Lending Rule, which requires financial institutions to compile and report certain data regarding business credit applications to the CFPB. The guide provides examples of how the rule applies to different scenarios, such as online and in-person applications, and outlines […]

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Section 1071 Q&A Week Two

Now that the Section 1071 rule is final, should we still be doing CRA Small Business as we do currently until we must begin the 1071 small business data collection based on the tier applicable to our loan volume? The OCC, the FDIC and the FRB in their 2022 notice of proposed rulemaking regarding CRA […]

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Section 1071 Q&A Week One

We know that loans will be reportable for both CRA and 1071. What if we collect DemographicInformation and the loan ends up being reportable for CRA? Being reportable for CRA does notdisqualify a covered transaction from being reported under 1071. The PDI would be reportedunder the obligation imposed by 1071. Which Data Points are interpreted […]

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Free up-to-date SBA Size Standards book from GeoDataVision

It is important for you to be aware that the term "small business," as outlined in Section 1071, specifically refers to the Small Business Administration (SBA) Regulations Part 121. In order to comply with the Section 1071 and to better understand the classification of a small business, it is essential to consult the updated Part […]

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Free Webinar: Comprehensive review of Section 1071 Rule

Presented by GeoDataVision in partnership with M&M Consulting Brace yourselves! On March 30th, the CFPB unleashed the long-awaited Dodd-Frank Section 1071 Rule, and it's about to shake the finance world to its core. Thought the CRA data file was a migraine-inducing burden? Section 1071's reporting requirements will make you beg for mercy. With a jaw-dropping […]

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Is a Big Fight with Bank Regulators Looming?

On February 13, the ABA Banking Journal bore a headline, "Nichols: ABA won't 'sit idly by', if regulators overstep their authority". The article went on to cite examples of rule making and regulatory changes "that will do more harm than good." In particular, the article identified the FDIC's plan to raise assessment fees and the […]

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Meaningful and Practical Climate Risk Analysis for Banks – The Climate Risks Banks Face Today

We all know that Climate-Related Risk regulations are in the process. The prudential bank regulators are not waiting for lawmakers to legislate climate risk law, they are actively drafting "guidance" and will be evaluating climate risk exposure as a "Safety and Soundness" issue. It's not yet official, but regulatory requirements are imminent. Already as exams […]

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“Figures don’t lie” but do regulators figure? Simpson’s Paradox says so

In emails in recent months we've warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ. The word is the DOJ is now approaching a record backlog of potential redlining cases. What we find particularly troublesome […]

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2021 reported Community Development and Consortium Lending for the entire country

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 very little information available about the Community Development Loan Market. GeoDataVision has captured all the 2021 reported Community Development and Consortium Lending for the entire country and has […]

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GAO Report Reveals Fair Lending MRA’s – Community Bank rate of issuing MRA’s more than doubles!

Dear Banker, Last year we learned that the Department of Justice Attorney General, Meritt Garland, announced an aggressive "Combatting Redlining Initiative." At GeoDataVision we've observed the impact of this action on a growing number of community banks. However, what came to light this summer in a report from the General Accounting Office is that the […]

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Dramatic Changes in 2022 Census
Tracts Compared to 2021 Tracts

Beware the Dramatic Implications for every bank! The effect of the switch-over from the census tracts for 2021 (based on the 2010 Census) and the 2022 tracts (based on the 2020 Census) cannot be overstated. Not only was there a very significant increase in the number of tracts (from 74,001 to 85,395 – a 15.4% […]

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Agencies ramp up redlining actions. Putting pressure on Community Banks to expand Assessment Areas

Since the beginning of 2022, we've noticed an increasing number of community banks being pressured to expand their Assessment Areas and to annex nearby urban areas. There have been too many examples that we have seen for this to simply be a coincidence. The phenomenon appears to be emanating from a much more aggressive policy mandate […]

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Just when you thought CRA couldn’t get more complicated – it just did!

Dear Banker, If the 2022 CRA NPR has you confused think again. Congresswoman Maxine Waters has just proposed legislation that makes the situation all the more confusing. Ms. Waters has just introduced a bill that would change the definition of small business and would mandate every bank to have "Community Advisory Committees" consisting of "a […]

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2020 reported Community Development and Consortium Lending for the entire country

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 very little information available about the Community Development Loan Market. GeoDataVision has captured all the 2020 reported Community Development and Consortium Lending for the entire country and has […]

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2022 MSA map available for free on the internet

GeoDataVision is pleased to announce the availability of free interactive Metropolitan Statistical Area Maps on the Internet. MSA's are a very important factor in Assessment Area delineation for CRA purposes. The map can be used to pan across and zoom into any area within the United States. You can even enter an address to see what MSA the address is located in. Feel free to […]

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Trident Mortgage

The Trident Mortgage redlining fine should be a reminder to compliance risk management officers about the Fair Lending pitfalls a lender can fall into. It is clear that the DOJ and the "Bureau" have marching orders that differ from that of their predecessors. GeoDataVision Fair Lending Guru, Rocky Pizzarello has developed a document that summarizes […]

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