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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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Is Fair Lending Enforcement Fair Today? Part II

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 and result in a market where a lender cannot compete on a level playing field […]

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How to Minimize Compliance Risk in the Radical New “Modern” Redlining Era

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 of referrals by the prudential bank regulators accusing banks of redlining. We at GeoDataVision have […]

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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 […]

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“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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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