Changes to 2024 MSAs Have Implications for CRA
In July 2023, the Office of Management & Budget published an update to “Core Based Statistical Areas, Metropolitan Divisions, and Combined Statistical Areas”. That document contains the latest...
View ArticleAssessment Areas under the new CRA rule – Estimated Standards to be available...
There has been much understandable confusion about many aspects of the new CRA rule. But perhaps there’s been no greater confusion and anxiety than about the Assessment Areas. And this anxiety has...
View ArticleNew CRA Retail Lending Test Benchmarks
The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many...
View ArticleThe Answers to the CRA Questions Everyone is asking: What must we do on April 1?
With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers. There are 3 sections of the new CRA that are...
View ArticlePostponement of April 1, 2024 “Applicable” Date May Cause More Confusion
The March 21, 2024, announcement that the prudential bank regulators have decided to postpone the scheduled April 1, “applicable” date for the Facility-based assessment areas, the new Public File...
View ArticleAdapting to Change: Navigating the New CRA Regulations and Planning Regions...
CT-2024-Census-Tract-ChangesDownload This webinar, presented by Len Suzio, focused on the new Community Reinvestment Act (CRA) regulations and their implications, especially considering the...
View ArticleWill the Regulators Implement a Key CRA Rule Component by Stealth?
Now that a Texas court has issued a temporary injunction delaying the April 1, 2024, scheduled implementation of the new CRA Rule should bankers relax and assume that the new rule’s effective date has...
View ArticleIs Fair Lending Enforcement Fair Today?
Every banker should know by now that the Department of Justice announced an “Anti-Redlining” crusade in October 2021. In his October 2021, press release, Attorney General Merrick Garland, proclaimed...
View ArticleAre Regulators Fairly Evaluating the Hottest Fair Lending Issue: Redlining?
Since October 2021, the prudential bank regulators in concert with the Department of Justice have been pursuing the “Anti-Redlining Initiative” announced by Attorney General Merrick Garland on October...
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Should the CFPB Reconsider the Implementation dates for Section 1071 data...
The recent Supreme Court ruling that upheld the constitutionality of the Consumer Financial Protection Bureau’s funding resulted in the Bureau announcing the new effective dates for banks to begin...
View Article“Manufactured” Redlining
In a recent article in National Mortgage Professional entitled "Manufacturing Fair Lending”, former chief of the Housing and Civil Enforcement Section at the Department of Justice under Attorney...
View ArticleChevron is History. Implications for the 2023 Community Reinvestment Act...
When the Supreme Court decided in favor of the plaintiff in Loper Bright Enterprises et al vs. Gina Raimondo it overruled its decision in Chevron v. Natural Resources Defense Council, the so-called...
View ArticleHow to Minimize Compliance Risk in the Radical New “Modern” Redlining Era
As any bank professional regulatory compliance professional knows redlining is the hottest issue today and has been since Attorney General Merrick Garland announced the “Combatting Redlining...
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Is Fair Lending Enforcement Fair Today? Part II
Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is...
View ArticleSection 1071 Rule: The Big Gap Between Small Business Lending and “Covered”...
I’ve written articles critical of the Section 1071 Rule and the CFPB’s implementation of the new rule. For example, the scheduled “applicable dates” for data recording and reporting make no sense at...
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The Killer ORLA Concept in the new CRA Rule
Readers of this article may think I am referring to Orcas, sometimes known as “killer whales.” But what I am referring to is the new form of Assessment Area in the 2023 CRA Rule. However, the...
View ArticleThe new Community Reinvestment Act Omits Critical Types of Credit That Meet...
Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule. But perhaps their frustration should be focused on the...
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Have Regulators Already “Raised the Bar” for CRA Exams?
Performance Ratings Indicate They Already Have When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance...
View ArticleThe Regulators Evolving Approach to Redlining Enforcement
During the last 15 years there have been notable changes in regulatory enforcement of potential redlining situations. This article addresses those changes. Originally, redlining prosecutions were...
View ArticleThere’s a New Sheriff Coming to Town What are the Implications for CRA and...
No sooner had President elect Trump’s win been announced that speculation began about the implications for bank regulations. “Trump Administration may upend banking industry,” proclaimed a headline in...
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