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Loans Community Reinvestment Act

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Section 1071 Rule: The Big Gap Between Small Business Lending and “Covered” Loans

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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 all. As currently...more

Ballard Spahr LLP

FDIC Chairman Gruenberg issues remarks at National Community Reinvestment Coalition on FDIC’s economic inclusion strategy

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FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy.  ...more

GeoDataVision

The Answers to the CRA Questions Everyone is asking: What must we do on April 1?

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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....more

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Assessment Areas Under the New CRA Rule – Estimated Standards to Be Available Soon

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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 become more acute the closer...more

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Changes to 2024 MSAs Have Implications for CRA

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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 definitions of Metropolitan...more

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How to Figure Out How the New CRA Affects Your Bank

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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 estimates of the regulators, if...more

Ballard Spahr LLP

Trade groups file lawsuit in Texas federal court challenging final OCC/FDIC/Federal Reserve Community Reinvestment Act rules

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Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community...more

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The new CRA: Surprises and Problems by Omission

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I have written a number of articles about the new CRA and the problems its requirements will impose on banks. But there are also problems posed by what the new Rule omits....more

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2022 Community Development Report by State

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One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is "Community Development Lending". But while Community Development Lending is critically important, there is very little information...more

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The Disastrous New CRA: Part III – It’s worse than you think and which banks are hurt the most

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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 impacted by the new Rule....more

Ballard Spahr LLP

The New CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 3

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This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

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New CRA Rule is a Disaster for Banks Part II: Key Regulator says Goal was “to raise the bar for CRA performance”

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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 Rule demonstrate that if...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 2

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This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks #1

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On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations...more

Alston & Bird

Affirmative Action in Lending: The Implications of the Harvard Decision on Financial Institutions

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The U.S. Supreme Court ruling ending race-based admissions at colleges and universities could have a ripple effect on unrelated fields. Our Financial Services & Products Group explores how the Harvard decision could change...more

Alston & Bird

Is the DOJ (De Facto) Enforcing the Community Reinvestment Act?

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A&B Abstract: Furthering the Justice Department’s Combating Redlining Initiative, the Department of Justice has announced another redlining settlement.  But this settlement is different – this one involves a bank that has...more

Goodwin

SEC Issues No-Action Relief On Registered Funds’ Custody Of Loan Interests

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In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more

Dechert LLP

Community Development Financial Institutions – Opportunities for Managers of Loan Funds and Venture Capital Funds

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Community Development Financial Institution (CDFI) certification is awarded to “community-based organizations that seek to expand economic opportunity in low-income communities and provide financial products and services to...more

Ballard Spahr LLP

The OCC’s final CRA rule: what changed from the agency’s proposed rule?

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On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. According to the agency’s press release, the final rule is designed to increase...more

Goodwin

Federal Agencies Encourage Access to Small-Dollar Loans in Light of COVID-19

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This week LenderLaw Watch covers developments related to small-dollar loans in response to the COVID-19 crisis. Every year the Board of Governors of the Federal Reserve System (Federal Reserve) conducts its Survey of...more

Robins Kaplan LLP

Financial Daily Dose 1.30.2020 | Top Story: Facebook Pays $550 Million to Resolve Privacy Class Action Over Use of Facial...

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Facebook has agreed to pay $550 million to resolve a class-action lawsuit claiming that Zuck & Co.’s use of facial recognition technology violated Illinois’ biometric privacy law. Though the settlement is little more than “a...more

Robins Kaplan LLP

Financial Daily Dose 1.9.2020 | Top Story: “Highlights” from Carlos Ghosn’s Accusatory Press Conference

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A recap of Carlos Ghosn’s big media moment on Wednesday, which was short on the escape details everyone wanted to hear and long on accusations against other execs at Nissan and Japan’s justice system....more

Troutman Pepper

CRA-like Standards for Fintechs Could Reduce Access to Credit

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As reported in American Banker, consumer advocacy groups are concerned that financial inclusion expectations for fintechs chartered as special-purpose national banks may not perfectly mirror the requirements of the Community...more

Ballard Spahr LLP

FDIC Chair’s recent interview gives insight into FDIC’s agenda

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In a recent interview (her first since being sworn in as Chair of the Federal Deposit Insurance Corporation), Jelena McWilliams provided insight into the FDIC’s likely regulatory agenda....more

Goodwin

Financial Services Weekly News - November 2017 #4

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Editor's Note - A Tale of Two Agencies. On November 27, Joseph M. Otting was sworn in as the 31st Comptroller of the Currency. Mr. Otting seamlessly succeeded Keith A. Noreika, who became Acting Comptroller in May 2017...more

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