Join top CRA experts Dr. Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act....more
7/31/2025
/ Banking Sector ,
Banks ,
Community Reinvestment Act ,
Compliance ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Insured Depository Institutions ,
Lenders ,
Loans ,
Regulatory Oversight ,
Regulatory Requirements
Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public...more
6/19/2025
/ Banking Regulators ,
Banks ,
Community Reinvestment Act ,
Competition ,
Data Collection ,
Disclosure Requirements ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
Loans ,
Regulatory Oversight ,
Regulatory Requirements ,
Small Business ,
Small Business Loans
Dear Banker,
Many bankers are easily confused by the technical requirements for loans in "disaster areas'' to be potentially qualified for community development credit under CRA. This brief article explains how to avoid...more
In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more
4/28/2025
/ Banks ,
Community Reinvestment Act ,
CRA ,
Financial Institutions ,
Loans ,
Mortgages ,
Multi-Family Housing ,
Notice of Proposed Rulemaking (NOPR) ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business ,
Urban Planning & Development
In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule:
1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment...more
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices,...more
4/4/2025
/ Banks ,
Community Reinvestment Act ,
Credit Ratings ,
Credit Reports ,
Creditors ,
Financial Regulatory Reform ,
Lenders ,
Loans ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Retailers ,
Trump Administration
Yesterday, as I was writing this article the news broke about the regulators deciding they intend to rescind the 2023 CRA rule. My first reaction was to toss this article in the “trash” folder. But upon further reflection I...more
3/31/2025
/ Banking Sector ,
Community Reinvestment Act ,
Creditors ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
Mortgages ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Small Business
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 ratings. Now that the final 2023 CRA performance ratings are in it...more
10/24/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
OCC ,
Performance Ranking Systems
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 regulators who have...more
10/9/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Loans ,
Mortgages ,
Multi-Family Development ,
Real Estate Transactions
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 analogy/metaphor may be...more
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
9/6/2024
/ Borrowers ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Section 1071 ,
Small Business Loans
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 collecting their CRA...more
5/31/2024
/ Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Reporting Requirements ,
Section 1071 ,
Small Business
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
3/20/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
HMDA ,
Lending ,
Loans ,
Low-Income Issues ,
Mortgages ,
Regulatory Requirements
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
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
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
2/21/2024
/ Banking Examinations ,
Banks ,
Benchmarks ,
Community Development ,
Community Reinvestment Act ,
Consumer Financial Products ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Mortgages
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
2/7/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
HELOC ,
Lending ,
Loans ,
Mortgages ,
Real Estate Transactions
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
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