Wild Times for the Community Reinvestment Act
Point-of-Sale Finance Series: The Great Debate of Loans vs. Credit Sales — The Consumer Finance Podcast
Explore the Impact of Point-of-Sale Finance in Our Upcoming Series — The Consumer Finance Podcast
Welcoming a New Payment Pro: Jason Cover Joins the Payments Pros Podcast — Payments Pros – The Payments Law Podcast
Insider Transaction Traps for the Unwary
Driven by Data: Auto Finance Trends Uncovered - Moving the Metal: The Auto Finance Podcast
Consumer Finance Monitor Podcast Episode: Everything You Want to Know About the CFPB as Things Stand Today, and Lots More - Part 1
Dialing In: The TCPA and Auto Finance — Moving the Metal: The Auto Finance Podcast
Williams Mullen Mezzanine Lending Video Series - Episode 5
Unlawful Debt Collection Claims - RICO Report Podcast
Advancing Agriculture - Identifying and Addressing Distressed Debts
Pillsbury's Industry Insights - Episode #22: Real Estate Market Update
Path Forward: Borrowing Base Redeterminations In A Restructuring World
THE WONDER YEARS WEBINAR
HEAVEN CAN WAIT
COVID-19 Comeback Plan: Part III - How Banks Think About Loan Defaults: Lessons for Borrowers in Troubled Times
THE WONDER YEARS WEBINAR - LOAN REGIME METHOD OF SPLIT DOLLAR LIFE INSURANCE
THE WAY WE WERE
Williams Mullen's Comeback Plan: Part II - How Banks Think About Loan Defaults: Lessons for Borrowers in Troubled Times
Join top CRA experts Dr. Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act....more
On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more
On July 1, the OCC released CRA performance evaluations for 22 national banks, federal savings associations, and insured federal branches of foreign banks, covering the period from June 1 through June 30. Of the evaluations...more
Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public...more
Dear Banker, Many bankers are easily confused by the technical requirements for loans in "disaster areas'' to be potentially qualified for community development credit under CRA. This brief article explains how to avoid...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
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
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
Recently, the OCC released data on small business, small farm, and community development lending during 2023, compiled by the FFIEC. The 2023 data, reported by 721 lenders, revealed a slight increase in reporting institutions...more
When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it...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
Readers of this article may think I am referring to Orcas, sometimes known as “killer whales.” But what I am referring to is the new form of Assessment Area in the 2023 CRA Rule. However, the analogy/metaphor may be...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
FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy. ...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
There has been much understandable confusion about many aspects of the new CRA rule. But perhaps there’s been no greater confusion and anxiety than about the Assessment Areas. And this anxiety has become more acute the closer...more
In July 2023, the Office of Management & Budget published an update to “Core Based Statistical Areas, Metropolitan Divisions, and Combined Statistical Areas”. That document contains the latest definitions of Metropolitan...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
One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is "Community Development Lending". But while Community Development Lending is critically important, there is very little information...more
In Parts I and II I explained the devastating impact of the new CRA Rule and what the underlying reasons for that adverse impact are. In Part III I will touch upon what banks are most significantly impacted by the new Rule....more
This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more
In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new Rule demonstrate that if...more
This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more
On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations...more