Knowledge Center

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|

A New Direction for State AML Compliance Roadmaps

Federal anti-money laundering (AML) regulations, rooted in the Bank Secrecy Act (BSA) and USA PATRIOT Act, have long required financial institutions to maintain internal control systems to assure compliance, provide for independent testing, designate individuals responsible for compliance and provide training for all appropriate personnel. Moving beyond this federal BSA/AML framework, the New York State [...]

October 18th, 2016|

Using BancorpSouth as a Learning Opportunity for Redlining

On June 29, 2016, a new case was added to the growing list of evidence signaling the importance of redlining as a key area of focus for Fair Lending compliance. In a joint effort between the Consumer Finance Protection Bureau (CFPB) and the U.S. Department of Justice (DOJ), BancorpSouth was accused of several discriminatory practices related [...]

July 19th, 2016|

Using Regression to Enhance Fair Lending Underwriting CFRs

In this contribution to ADI Adviser, ADI Senior Economist Paul J. Strasberg discusses how integrating modeling results can enhance the selection of comparators for a comparative file review (CFR) in a Fair Lending analysis of underwriting. Paul demonstrates how the use of propensity score matching (PSM) "effectively removes the judgments that a lender’s compliance analyst might make when [...]

June 28th, 2016|

Evaluating Redlining Risk in Mortgage and Consumer Lending

In recent years, the Department of Justice (DOJ) and various federal, state, local and non-profit entities have generated many headlines about identifying and pursuing cases of redlining against financial institutions. Recent cases include: a $33 million settlement between Hudson City Savings Bank and the DOJ; an $825,000 settlement between Evans Bank and the Attorney General [...]

June 16th, 2016|