CRA

Federal Reserve releases proposals on CRA modernization

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 [...]

September 22nd, 2020|

Banking Agencies Issue Joint Statement on Enforcement of BSA/AML Requirements

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 [...]

August 17th, 2020|

Redlining Violations Include Discouragement and Low Application Volume

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 [...]

July 16th, 2020|

CFPB Issues Interpretive Rule on Method for Determining Underserved Areas

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 [...]

June 25th, 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|

ADI Announces Availability of Preliminary Snapshot of National 2018 HMDA Data

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 [...]

April 19th, 2019|

Liberty Bank Settles in Lawsuit Alleging Discriminatory Lending

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 [...]

March 8th, 2019|

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|