Under the Community Reinvestment Act (CRA), examiners will assess the community credit and development needs in a bank’s assessment area. A community credit needs assessment – which may also be referred to as a community needs assessment – is a component of the analysis of performance context in a CRA examination. It is intended to [...]
Get It Right: It’s a mantra for HMDA reporting, and it’s equally critical in CRA small business reporting for regulatory compliance. Three of the four critical fields to CRA reporting routinely cause lenders problems: Loan Amount, Loan Location and Gross Annual Revenues of $1 Million or Less. The right answer depends on such specifics as [...]
In May 2022, The Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve System proposed changes to the Community Reinvestment Act (CRA), including reclassification of small, intermediate, and large banks; new qualitative and quantitative test processes, and clarifying the definition of Community Development, with [...]
The Justice Department has announced a settlement with Houston-based Cadence Bank to resolve allegations that the bank engaged in lending discrimination by ‘redlining’ predominantly Black and Hispanic neighborhoods in the Houston area. The Department alleged that the bank engaged in redlining between 2013 and 2017 by avoiding providing loans and other home mortgage services in majority-Black [...]
On February 4th, State financial regulators cited Buffalo-based Hunt Mortgage Corp. (Hunt) for weakness in lending to minorities and minority neighborhoods, as they released a report finding an overall lack of lending by nonbank mortgage companies in Buffalo, despite laws banning the practice of redlining. Hunt is a subsidiary of Hunt Real Estate Corp., the [...]
Download This Article With the transition between presidential administrations, new regulations, and the ongoing effects from the pandemic and corresponding economic crisis, lenders are facing a dynamic environment in 2021 with respect to managing compliance risk under Fair Lending laws and the Community Reinvestment Act (CRA). There is another factor, however, receiving less attention but [...]
The Federal Reserve Board (FRB) released a draft advance notice of proposed rulemaking (ANPR) on September 21, 2020 related to its effort to modernize its approach to supervising institutions under the Community Reinvestment Act (CRA). This effort seeks to make changes by “strengthening, clarifying, and tailoring” the FRB’s CRA framework. The FRB has several objectives [...]
On July 15th, the Consumer Financial Protection Bureau (CFPB) filed suit against Townstone Financial, Inc. for violations of the Equal Credit Opportunity Act (ECOA), Regulation B, and the Consumer Financial Protection Act (CFPA). This case is interesting for several reasons, not the least of which are that – The CFPB suggests that the violations noted [...]
On June 23rd, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule to provide guidance to creditors and other persons involved in the mortgage origination process about the way in which the Bureau determines which counties qualify as “underserved” for a given calendar year. issued Tuesday. The guidance is necessary, the CFPB said, because [...]
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 [...]
