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 August 13th,the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (the Agencies) issued joint guidance to clarify and update policies addressing the enforcement of the Bank Secrecy Act’s (BSA’s) anti-money laundering (AML) program requirement. The guidance, which replaces a prior interagency statement from [...]
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 [...]
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 [...]
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 [...]
On March 29, 2019, the Consumer Financial Protection Bureau (CFPB) released the Modified Loan Application Registers (LARs) reflecting 2018 mortgage lending activity reported under the Home Mortgage Disclosure Act (HMDA). These reports represent the first release of HMDA data under the new rule implemented in 2015. Starting in 2018, under the 2015 HMDA Rule, financial [...]
Liberty Bank, based in Middletown, CT, has agreed to invest millions to make banking services and loans more available to people of color after settling a lawsuit that alleged the Middletown-based company was discriminating against minorities. The agreement comes after the Connecticut Fair Housing Center and the National Consumer Law Center last fall filed a lawsuit [...]
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 [...]
