Knowledge Center

Borrower Experience in the Loss Mitigation Process

Note: This is a cross-post from Person to Person Quality, a division of ADI Consulting. The era of COVID-19 has created unprecedented short-term disruption in the lives of millions of individuals and families. Record-high unemployment, reduced work hours, and rising costs have affected millions of people. For many households, these events create difficulties in making [...]

June 24th, 2020|

Compliance in the Era of COVID-19: Managing Risk While Meeting Consumer Needs

Lending institutions play a unique and vital role in helping consumers and businesses recover from heavy economic hardships during the COVID-19 pandemic. Businesses are affected by the pandemic in differing ways:  for some it means a slight reprieve in activity and possible opportunity to implement system improvements. For lenders, however, it often necessitates rapidly processing [...]

June 1st, 2020|

Compliance in the Era of COVID-19: The CRA

The current crisis caused by the COVID-19 pandemic has dramatically changed American society.  The tragic loss of life and unparalleled social and economic disruption make it difficult to imagine any community and industry that will not face long-term effects. More than a decade removed from the housing crisis and the resulting Great Recession, banks once [...]

May 21st, 2020|

Ramping up, rather than letting up on compliance during COVID-19

  Banking regulators are temporarily reducing their examination schedules. At first glance, this reduction may seem to indicate that it is appropriate to ditch your compliance hat until the current quarantine period is behind us. Hold on to that hat though – while the examination schedule is delayed, regulatory requirements continue, and this new environment [...]

April 28th, 2020|

Paycheck Protection Program & BSA Compliance

On March 27, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) to provide emergency assistance for those affected by the coronavirus pandemic. As part of the CARES Act, the U.S. Small Business Administration (SBA) received funding and authority to assist small businesses nationwide that have been adversely impacted by the COVID-19 emergency. In its Interim Final Rule (the Rule),  the SBA sets out [...]

April 14th, 2020|

Does Your CRA Assessment Area Present Redlining Risk?

In May 2018, the Department of Justice (DOJ) reached a settlement with KleinBank regarding a Redlining-related lawsuit filed by the DOJ against the bank in January 2017.  In the lawsuit, the DOJ alleged the bank “engaged in unlawful redlining of majority-minority neighborhoods in the Minneapolis-St. Paul metropolitan area” from 2010 through 2015. The DOJ found [...]

January 10th, 2019|

The Modern CRA Service Test: 6 Trends That Banks Need To Know

Download This Article While banks have operated under the Community Reinvestment Act (CRA) for 40 years, the range of CRA Services they provide to meet the Service Test has grown.  Over this period, banks have responded in many creative and impactful ways to meet the needs of their communities, particularly in services. The Service Test [...]

December 18th, 2018|

The Investment Test: What Banks Need to Know

Banks have operated under the Community Reinvestment Act (CRA) for 31 years.  The CRA requires banks to help meet the needs of low- and moderate-income (LMI) persons and distressed geographies through lending, investment, and service.   Over this period, banks have responded in many creative and impactful ways to the needs of their communities, particularly in [...]

August 13th, 2018|

How Controlling for Local Competitive Environments May Reduce Fair Lending Pricing Risk

Lenders operating across multiple metro areas, in ADI’s experience, provide their branches with national rate sheets through which they price first-lien mortgages. Despite the single rate sheet, the lender’s many branch managers confront different competitive environments and are often tasked with refining rate sheet-based pricing to meet local conditions and maximize loan originations. Branch Manager [...]

July 11th, 2018|

2016 HMDA Data Highlights [Infographic]

On September 28, 2017, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of 2016 mortgage lending data submitted in compliance with the Home Mortgage Disclosure Act (HMDA). This database of mortgage activity is relied upon by regulators, examiners, academics, industry leaders, and members of the general public to analyze the performance of mortgage lenders with regard [...]

October 5th, 2017|