Mortgages, Community Reinvestment Act

How to Minimize Compliance Risk in the Radical New “Modern” Redlining Era

GeoDataVision on 7/25/2024

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 Initiative” in October 2021. Since...more

“Figures don’t lie” but do regulators figure? Simpson’s Paradox says so

GeoDataVision on 6/13/2024

In emails in recent months we've warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ....more

Nutter Bank Report: May 2024

Nutter McClennen & Fish LLP on 5/31/2024

Headlines 1. Supreme Court Upholds the Constitutionality of the CFPB’s Funding Structure The Supreme Court has ruled that the statutory authorization that allows the CFPB to draw funds from the earnings of the Federal Reserve...more

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

GeoDataVision on 3/20/2024

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

New CRA Retail Lending Test Benchmarks

GeoDataVision on 3/18/2024

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 bankers, although not...more

The Potentially Adverse Fair Lending Implications of the New CRA Rule

GeoDataVision on 2/26/2024

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 performance standards...more

How to Figure Out How the New CRA Affects Your Bank

GeoDataVision on 2/21/2024

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

The new CRA: Surprises and Problems by Omission

GeoDataVision on 2/7/2024

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

Redlining Was Outlawed More than 50 Years Ago – Does It Still Continue?

Whitman Legal Solutions, LLC on 2/5/2024

Recently, my son took an online college course about social justice in the as-built environment. One topic in the class was redlining – a practice that limited the availability of affordable home loans for minorities. ...more

Illinois proposes rule to evaluate mortgage community reinvestment

Orrick, Herrington & Sutcliffe LLP on 1/29/2024

Recently, the Illinois Department of Financial and Professional Regulation issued a proposed rule pursuant to the Illinois Community Reinvestment Act (ILCRA). The ILCRA is modeled off the Community Reinvestment Act but...more

What is a “REMA” and why is it so important?

GeoDataVision on 1/18/2024

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 22, 2021, by Attorney...more

CFPB Publishes New Report on State Community Reinvestment Laws

Sheppard Mullin Richter & Hampton LLP on 11/10/2023

On November 2, the CFPB issued a new report on state Community Reinvestment Act laws. The report found that many states adopted Community Reinvestment Acts (CRAs) similar to the federal Community Reinvestment Act of 1977. The...more

Federal, State Agencies Promote Expanded Oversight of Bank and Nonbank Community Development Activities

Cooley LLP on 11/10/2023

On November 2, 2023, the Consumer Financial Protection Bureau (CFPB) issued a survey on state Community Reinvestment Acts (CRAs) aimed at informing states without CRAs about actions they could take to promote lending and...more

Federal Banking Regulators Issue Final Rule Overhauling Community Reinvestment Act Regulations

Pillsbury Winthrop Shaw Pittman LLP on 10/30/2023

The expansive final rule overhauls how banks are evaluated for lending to low- and moderate-income customers. The federal banking regulators issued a joint final rule that will govern Community Reinvestment Act (CRA)...more

DOJ Redlining Consent Order With Ameris Bank

Ballard Spahr LLP on 10/30/2023

Recently the U.S. Department of Justice (DOJ) entered into a proposed consent order with Ameris Bank to resolve allegations of redlining from 2016 through 2021 in majority Black and Hispanic areas in the Bank’s Jacksonville,...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2023

Troutman Pepper on 7/6/2023

To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more

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

Alston & Bird on 10/19/2022

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

DOJ announces settlement of redlining lawsuit

Ballard Spahr LLP on 10/4/2022

The Justice Department announced that it has entered into an agreement with Lakeland Bank to settle the DOJ’s claims that Lakeland engaged in unlawful redlining in the Newark, New Jersey metropolitan area. The DOJ’s lawsuit...more

State Community Reinvestment Acts Reaching Beyond Banks

Alston & Bird on 9/27/2022

A&B ABstract: When Congress passed the federal Community Reinvestment Act (“CRA”) in 1977 to address redlining, it imposed affirmative requirements on insured depository institutions to serve the credit needs of the...more

New fair banking CRA legislation: House committee on financial services (HR 8833)

BCLP on 9/21/2022

US House of Representatives Committee on Financial Services Chairwoman, Maxine Waters (D-CA), has introduced new legislation H.R. 8833 “Making Communities Stronger through the Community Reinvestment Act.” The proposed...more

New York amends its Community Reinvestment Act to cover non-bank mortgage lenders; New York DFS issues proposed revisions to CRA...

Ballard Spahr LLP on 11/16/2021

Expansion of CRA coverage. On November 1, New York Governor Hochul signed into law amendments (S.5246-A/A.6247-A) to the New York Community Reinvestment Act (NYCRA) that expand the NYCRA’s coverage to non-depository mortgage...more

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