Community Reinvestment Act

News & Analysis as of

CFPB Deems Federally-Approved CRA Assessment Area to Be Discriminatory

The Federal Community Reinvestment Act (“CRA”) requires regulated financial institutions to focus on meeting “the credit needs of the local communities in which they are chartered.” See 12 U.S.C. § 2901(a)(3). Under the CRA,...more

Hudson City Savings Bank Reaches Largest Mortgage Redlining Settlement in DOJ History

The CFPB, DOJ, and Hudson City Savings Bank, F.S.B. (“Hudson City”) recently entered into the largest residential mortgage redlining settlement in DOJ history. On September 24, 2015, the parties filed a Joint Motion for Entry...more

New York City’s RBA Falls to Preemption Challenge

New York City banks are breathing a sigh of relief after a federal judge ruled that they would not have to provide detailed servicing disclosures under a preempted city law. The law, a gloss on top of the federal Community...more

CFPB Brings Long-Anticipated First Redlining Enforcement Action – New Approach to Redlining Analysis is put into Action

On September 24, 2015, the CFPB and DOJ announced a joint action against Hudson City Savings Bank for allegedly discriminatory redlining practices from 2009 through 2013 in certain neighborhoods in New York, New Jersey,...more

CFPB and DOJ announce redlining settlement

Consistent with recent indications from CFPB and Department of Justice officials that more redlining cases would soon be coming, the CFPB and DOJ have announced a proposed consent order with Hudson City Savings Bank to settle...more

Banks Get Big Win in Challenge to New York Ordinance

Many big cities in the United States responded to the fallout from the 2008 financial crisis by passing local laws which pressure banks to invest more in low-income neighborhoods. Between 2010 and 2013, cities such as New...more

CFPB and DOJ Announce Joint Action Against Hudson City Savings Bank, F.S.B.

On September 24, 2015, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) announced a joint action against Hudson City Savings Bank, F.S.B. (Hudson). The complaint alleges that Hudson...more

Ferguson Commission Urges Greater Access to Banking in Disadvantaged Communities

This week, the Ferguson Commission released an analysis of the socio-economic environment following the shooting of Michael Brown that included recommendations for financially strengthening lower-income areas. The Commission,...more

District Court Invalidates NYC Ordinance Making Banks Service Under-Served Areas as Requirement to Receive Municipal Deposits

On August 7, the U.S. District Court for the Southern District of New York granted summary judgment for the New York Bankers Association (NYBA) in a case challenging the City of New York’s Local Law 38, entitled the...more

Comptroller Supports More CRA Credit for Small Business Lending while CRA Protests Continue to Stall M&A Deals

Why it matters - In recent remarks at the State Small Business Credit Initiative Conference, Comptroller of the Currency Thomas J. Curry discussed the state of small business credit programs, emphasizing the “crucial...more

(US) Are Small Business Administration 504 Loans Exempt from High Volatility Commercial Real Estate Regulations?

As discussed in a prior blog , Basel III regulations governing high volatility commercial real estate (HVCRE) went into effect. The HVCRE rules require lenders to assign a higher risk weighting to loans for the acquisition,...more

Financial Regulatory Developments Focus - January 2015 #3

In this issue: - US Office of the Comptroller of the Currency Releases Community Reinvestment Act Evaluations - Amendment to Regulation on Supervisory Reporting of Institutions on Asset Encumbrance, Single Data...more

The Economic Development Toolbox: “The Clean-Up Hitters” – Enterprise Zone and Community Reinvestment Area Property Tax Exemptions

Capital investment projects often involve tight margins, and every single dollar counts to ensure that the project is a success. For that reason, property tax exemptions are key components of any economic development...more

One small step for FHFA, one giant step for affordable housing and community reinvestment across the country

In what may be one of the longest tests of perseverance and intestinal fortitude in the history of legislative advocacy for affordable housing, supporters of the National Housing Trust Fund (NHTF) finally saw their proposal...more

Agencies Propose Revisions to Q&A on Community Reinvestment

On September 8, the Fed, FDIC and OCC proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. The Q&A provides guidance on the implementation of the Community Reinvestment Act (CRA)....more

Prudential Regulators Seek Comments On Proposed CRA Questions And Answers

On September 8, the OCC, the FDIC, and the Federal Reserve Board released proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. Specifically, the agencies propose to revise three...more

Banking Agencies Request Comment on Proposed Questions and Answers Regarding Community Reinvestment

On September 8, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency requested comment on proposed revisions to the “Interagency...more

Comments requested regarding proposed guidance on the Community Reinvestment Act

The Office of the Comptroller of the Currency, Treasury, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation are the federal agencies that implement the Community Reinvestment...more

Can You Satisfy CRA Requirements and Still Make Money? Try SBICs

Have you considered an investment in or creating a Small Business Investment Company? Doing so may provide financial institutions with a number of benefits, including credit toward annual investment requirements under the...more

The Community Reinvestment Act (CRA): Recap and What to Expect in 2014 [Video]

The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation adopted as final the Interagency Questions & Answers (Q&As) regarding...more

Three Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions

On December 19, the Fed, FDIC and OCC announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank and intermediate small savings association under...more

Federal Banking Agencies Issue Interagency Statement on Supervisory Approach to Qualified Mortgage Loans

The FDIC, OCC, NCUA and FRB issued an interagency statement on the supervisory approach to originating qualified mortgages under the CFPB’s ability-to-repay and qualified mortgage rule finalized in January 2013 and...more

Prudential Regulators Address Impact Of QM Lending On CRA Ratings

On December 13, the Federal Reserve Board, the FDIC, the OCC, and the NCUA issued an interagency statement to clarify safety and soundness expectations and CRA considerations in light of the CFPB’s ability-to-repay/qualified...more

The Community Reinvestment Act (CRA): New And Revised Interagency Questions And Answers Leaves Some Questions

The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corporation (FDIC) (collectively the Agencies) adopted as final the Interagency...more

Social Media: Consumer Compliance Risk Management Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to...more

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