2023 CRA Rule Repeal: Lessons to be Learned
The fatal flaws in the 2023 CRA rule
Predictions regarding the 2023 CRA Rule and Section 1071 and how to prepare for expected developments
How to estimate how your performance will look under the new CRA
2024 Regulatory Hot Topics
The Coming Perfect Storm
The Importance of Assessment Areas
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Keeping up with all the new regulations
What’s behind the increase in CRA Exam failures?
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
As federal agencies pull back on consumer protection regulations under the Trump administration, California is stepping up to fill the void. This shift was forecasted in January, when the Consumer Financial Protection Bureau...more
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is...more
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The...more
During the Biden-Harris Administration, the relationship between financial institutions and their regulators chilled considerably. The financial services industry works daily with its regulators—especially through the...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
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
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
On November 2, 2023, the Consumer Financial Protection Bureau issued a report on the community reinvestment laws of seven states (Connecticut, Illinois, Massachusetts, New York, Rhode Island, Washington, West Virginia), and...more
The federal banking agencies have jointly issued a final rule that will modify how examiners assess compliance with the Community Reinvestment Act (CRA). Among other changes to the CRA regulations announced on October 24, the...more
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
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
Banking Law Rooted in Civil Rights Era Gets a 21st Century Update "The Community Reinvestment Act basically mandates that if you open a bank in a low-income neighborhood, you can’t just take that neighborhood’s deposits and...more
Regulatory Developments - Agencies Issue Joint Proposal to Strengthen and Modernize CRA Regs - On May 5, the FDIC, the FRB and the OCC issued a joint Notice of Proposed Rulemaking (NPR) to “strengthen and modernize” the...more
Regulators took a first step toward modernizing CRA regulations with a joint Notice of Proposed Rulemaking. The proposed rule would add more standardized metrics for regulators’ CRA examinations and more clearly delineate...more
Please join us for the annual Nelson Mullins Financial Services Conference, which will feature a lineup of national speakers on the future of financial services....more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more
FDIC Board Governance Dispute on Review of Bank Mergers Aired Publicly - CFPB Director Rohit Chopra on December 9 published on the CFPB’s website a blog post captioned “How Should Regulators Review Bank Mergers?” in...more
At the beginning of his term, President Biden declared that his administration would make it a policy to eliminate “racial bias and other forms of discrimination in all states of home-buying and renting.”...more
In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it will reconsider its controversial June 2020 final rule revising its Community Reinvestment Act (CRA) rules, and published its Semiannual...more
Federal Reserve Issues New Guidance on Managing the LIBOR Transition - The Federal Reserve has issued guidance on how examiners will assess a banking organization’s progress in preparing to transition to a replacement rate...more
In this Issue. The U.S. Department of the Treasury announced that it was opening the application process for the Emergency Capital Investment Program, a new program designed to provide long-term, low-cost equity and...more
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
In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...more