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
Now that the Trump Administration has announced its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule. It was unbelievably complex, confusing and...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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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