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New CRA Rule is a Disaster for Banks Part II: Key Regulator says Goal was “to...
In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new...
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The Disastrous New CRA: Part III – It’s worse than you think and which banks...
In Parts I and II I explained the devastating impact of the new CRA Rule and what the underlying reasons for that adverse impact are. In Part III I will touch upon what banks are most significantly...
View ArticleThe Disastrous New CRA Rule: Part IV – Is the 80% Retail Lending Assessment...
Dear Banker, The new CRA Rule contains a "break" for Large banks that would exempt them from having to declare Retail Lending Assessment Areas ("RLAAs") for any calendar year in which the bank lends...
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Part V; A Critical Review of Serious Flaws in the New CRA
Most of the articles published about the new CRA rule have repeated the party line – that the new rule “modernizes” the Regulation, that it will make CRA exams more objective and CRA ratings more...
View ArticlePart VI: The New CRA Rule: Another Surprise – for Banks and maybe for the...
The new CRA Rule has a number of surprises for banks and maybe a surprise or two for the regulators themselves. One of those surprises involves the transition rules in §__.51 as they pertain to the...
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2022 Community Development Report by State
2022 CRA data released by the FFIEC December 2023 Ordered Alphabetically by State One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is "Community Development...
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Coming Soon: Climate Risk Assessments for Banks – Are You Ready?
Climate Risk Assessments for banking purposes are in the early stages of development. No laws or regulations have been issued regarding the topic. Nonetheless, it is obvious that lawmakers and...
View ArticleWhat is a “REMA” and why is it so important?
As I write this article the Department of Justice is pursuing a record-breaking number of “redlining” cases against banks and mortgage lenders. The “Anti-redlining Initiative” was announced October...
View ArticleThe new CRA Rule: Confusion Reigns
Our office has been inundated with inquiries about an aspect of the impact of the impending new CRA rule. As we have noted in previous articles there are mistakes and inconsistencies in the new CRA...
View Article2024 CRA Q&A
How will loan data collection change given the pause on the 1071 rule? If that's not a topic for today, where can I find a good source for information regarding loan data collection? I would not make...
View ArticleHow to Figure Out How the New CRA Affects Your Bank
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the...
View ArticleThe Potentially Adverse Fair Lending Implications of the New CRA Rule
There has been much understandable handwringing about the new CRA and its complexity as well as the high CRA exam failure rate predicted by regulators based on the new assessment areas and the higher...
View ArticleChanges 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...
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