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
On September 22, 2017, multiple government agencies announced “… a proposed rule that would revise their regulations implementing the Community Reinvestment Act (CRA) (12 USC 2901 et seq.). The proposed rule would amend the...more
Many of us in banking were glad to see 2012 come to a close and hopeful for a better 2013. To the extent that better means fewer regulatory issues, now is the time to prepare your bank’s Home Mortgage Disclosure Act (“HMDA”)...more