On June 18, 2025, the CFPB published its 2025 Section 1071 Interim Final Rule. Lenders covered by the 2024 Section 1071 Interim Final Rule should know what the 2025 Rule is changing, how it affects them and what they can and...more
6/26/2025
/ Compliance Dates ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Final Rules ,
Interim Final Rules (IFR) ,
Lenders ,
Mortgage Lenders ,
Mortgages ,
Regulatory Requirements ,
Reporting Requirements ,
Section 1071 ,
Small Business Loans
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
Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is called a “REMA” or...more
8/27/2024
/ Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Redlining ,
Regulatory Requirements
Many bankers hear the term “Statistical Significance” but don’t know what it means and how it is relevant to potential fair lending violations. Typically, when an examiner is evaluating if a bank is redlining, they will...more
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
7/25/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining ,
Risk Management
In a recent article in National Mortgage Professional entitled "Manufacturing Fair Lending”, former chief of the Housing and Civil Enforcement Section at the Department of Justice under Attorney General William Barr, Paul...more
6/17/2024
/ Banks ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
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
6/13/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
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 that redlining is...more
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
2/26/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
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
1/18/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining