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
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
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
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
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
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
Editor's Note - A Tale of Two Agencies. On November 27, Joseph M. Otting was sworn in as the 31st Comptroller of the Currency. Mr. Otting seamlessly succeeded Keith A. Noreika, who became Acting Comptroller in May 2017...more
On September 24, 2015, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) announced a joint action against Hudson City Savings Bank, F.S.B. (Hudson). The complaint alleges that Hudson...more