The FDIC and the OCC have published a Notice of Proposed Rule-Making for the Community Reinvestment Act ("CRA"). The NPR contains radical changes that dramatically affect the CRA responsibilities of every bank. You need to know what the proposed changes are and you should contact the FDIC and/or the OCC about them before it is too late!
The proposed changes are dramatic and will affect all banks in big ways.
Some of the changes include:
We have received an enormous interest in the special table we prepared that summarized the changes in tract income class from 2018 to 2019. Many bankers have asked if GeoDataVision would publish a list of specific census tracts that experienced a change in tract income classification from 2018 to 2019.
Every year we invariably consult for banks who have "lending gaps" in their Assessment Areas. In a surprising number of cases it turns out that some of the tracts are "underwater tracts". Most banks don't even know there are any underwater tracts in their Assessment Area. All they know is they never lend in some tracts (and if they do have loans in underwater tracts they may want to verify their geocoding!)
The FFIEC recently published the 2019 Census Demographic files that are the basis for the Community Reinvestment Act (CRA) tract income classifications.
- Thirty-three states plus the District of Columbia and Puerto Rico had tracts whose income class was changed.
- Seventeen states had no tracts with income class changes
- The states with the most tracts whose income class changed were New York and New Jersey
- A total of 1,190 tracts had their income class changed from 2018 to 2019
For more information, contact Bob Suzio at 203-245-2750.
On February 9, at the 2016 CRA Conference in Los Angeles the Comptroller of the Currency, Thomas Curry, announced a draft of a soon-to-be-published proposal to encourage banks to help revitalize "targeted" neighborhoods by engaging in higher loan-to-value mortgages.