CRA

CFPB Publishes 2015 Report on Consumer Complaints

On April 1, 2016, the CFPB published its 2015 Consumer Response Annual Report. This annual report summarizes trends the CFPB has identified from 271,600 complaints that it accepted from financial product consumers during 2015. These complaint data can be a useful source of insight for banks and lenders to identify general areas that require attention [...]

April 5th, 2016|

Kansas City Lender to Pay 2.8 Million in Redlining Case with HUD

First Federal Bank of Kansas City has agreed to a $2.8 million settlement with the Department of Housing and Urban Development to resolve allegations of redlining in African-American neighborhoods.  As part of the conciliation agreement, First Federal agreed to originate $2.5 million in loans in majority African-American census tracts over a three-year period.  The settlement  also [...]

March 1st, 2016|

Return of Redlining and Steering Cases

The American Banker reported on September 4 that Justice Department and HUD officials signaled again that more redlining and steering cases are under investigation. "Based on what is on my docket right now, stayed tuned," said Steven Rosenbaum, chief of housing and civil enforcement at DOJ's civil rights division, during a HUD-sponsored Fair Housing conference. [...]

September 4th, 2015|

Down Payment Misperceptions May Be Limiting Fair Lending and CRA

According to a recent survey conducted by Wells Fargo, a majority of African Americans and Hispanics believe that a 20 percent down payment is required to purchase a new home (source: Boston.com, 8/3/15): Consumers also overestimated the amount of money needed for down payment funds to qualify for a home loan, with 36 percent believing [...]

August 5th, 2015|

Q2 Results for Top Lenders Signal Strong Mortgage Market

Second quarter 2015 financial results for Wells Fargo and JPMorgan Chase signal a strong rebound in the mortgage market from 2014. This growth was attributed to healthy demand in the home purchase market, based on improving economic conditions, affordable home prices, and continued low interest rates (MarketWatch.com, 7/14/2015): “It was a strong quarter” for the purchase market, [...]

July 16th, 2015|

“Unreasonable” LTD Ratio Leads to a CRA Rating of NI for Miami-area Bank

The July 2015 release of CRA performance evaluations by the FDIC offers an example of how the loan-to-deposit (LTD) ratio test can over-shadow satisfactory performance in other tests under CRA. According to FDIC examiners, the LTD ratio for Intercontinental Bank of West Miami, FL did not meet expectations: The average net loan-to-deposit ratio of 21 percent is [...]

July 7th, 2015|

ACLU Studies Impact of Housing Crisis on the Wealth Gap

According to a study commissioned by the American Civil Liberties Union (ACLU), the recovery following the housing crisis has diverged between minority and non-minority families. While white families showed a stronger recovery during the period of 2009-11, black families continued to see their wealth decline. A principal reason cited for this is the difference in sources [...]

July 2nd, 2015|

The CD Test Prevents a Bank from Getting a “Satisfactory” CRA Rating

Among the round of CRA ratings released for April 2015, the 2015 performance evaluation (PE) of Belmont Savings Bank (Belmont) highlights how a poor evaluation under the Community Development (CD) test can overshadow satisfactory lending to low- and moderate-income (LMI) geographies and borrowers: Overall, Belmont’s level of CD lending since the previous evaluation demonstrates poor [...]

April 20th, 2015|

Evaluating the CRA Performance of a Midwestern Mortgage Lender

ADI helps a mortgage lender assess its CRA lending performance in the Midwest. Assessing the Challenge A large bank headquartered in the Midwest engaged ADI to evaluate its CRA lending performance in both its full- and limited-scope assessment areas. In a previous CRA performance evaluation, the bank received an overall CRA rating of Satisfactory, but with a [...]

April 8th, 2015|

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