The Community Reinvestment Act mandates that a bank meets the credit needs of the communities which it serves as delineated by its CRA assessment areas. The regulation has a simple test to address that issue. It’s called the “CRA Assessment Area Concentration Ratio” which calculates the […]
Read moreDoes it do the job? On December 17, 2025, the Office of the Comptroller of the Currency (OCC) published proposed new guidance that is intended to streamline the process for a CRA-covered financial institution to obtain approval of a CRA strategic plan. Will the proposed changes […]
Read moreOne of the headline-leading compliance issues during 2025 has been the Trump Administration’s announcement in Executive Order 14281(“Restoring Equality of Opportunity and Meritocracy”) to “seek to eliminate the use of disparate impact liability in all contexts to the maximum degree possible.” The focus of media coverage […]
Read moreThere’s a lot of things in the world of bureaucratic regulations that don’t appear to make sense and can be downright funny and frustrating at times. For example, when I was in the state senate in Connecticut the Department of Information Technology was known as “DOIT”. […]
Read moreThe CFPB’s Section 1071 Proposal: Big Reduction in Reporters, Loans and Data Points Does Drastic Reduction in Reporters and Loans Undermine Purpose? The CFPB’s proposal to modify the Section 1071 Rule offers significant reporting relief (and some complications) in several ways: (1) the change in the […]
Read more2024 CRA Aggregate & Disclosure Data was released by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as regulatory compliance purposes. We are making available the statewide Small Business Loan Market Rank […]
Read moreThe 2024 CRA Aggregate & Disclosure Data was released by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as regulatory compliance purposes. We are making available the statewide Small Business Loan Market Rank […]
Read moreAbout 83% of CRA “covered” lenders do not report lending under CRA On November 13, the Federal Bank Regulatory Agencies announced the availability of the 2024 CRA lending activity of 731 lenders who reported data on their small business and small farm lending, as well as […]
Read moreA golden opportunity has been lost On November 7, the FDIC announced a change to the consumer compliance examination cycle. Consumer compliance issues pertain to topics including Truth in Lending, Real Estate Settlement Procedures, Flood Insurance, the Equal Credit Opportunity Act, The Fair Housing Act, the […]
Read moreEven before President Trump was sworn into office on January 20, 2025, the banking community and community activists were abuzz about the Trump Administration’s announced intentions to relax regulatory enforcement. One of the primary manifestations of the Administration’s approach is reflected in the announcement by bank […]
Read moreIn October 2021, the then Attorney General, Merrick Garland, announced the Combating Redlining Initiative (“CRI”) Shortly thereafter, federal banking regulators began a record-breaking number of referrals to the Department of Justice for alleged “redlining.” A key factor in all those referrals, was the use of “statistical […]
Read moreIf you are worried about “redlining” you’d better understand statistical significance The perennial question facing all banks is, “What volume of lending in Majority-Minority census tracts and mortgages extended to minority home borrowers must we do to avoid redlining allegations by bank regulators?” The answer provided […]
Read moreThe FFIEC released the official 2024 HMDA Aggregate & Disclosure file in June. GeoDataVision uses that data to create special market rank and market share reports for markets everywhere in the USA. This data is invaluable for CRA and Fair Lending analysis and is the same […]
Read moreDear Senators, I have been a consultant regarding the Community Reinvestment Act since 1994 and have advised hundreds of banks and occasionally a community group about an institution’s CRA responsibilities. I am one of the few people in the country who thoroughly read and understood the […]
Read moreIf they did here’s one way to handle it Under the Biden Administration the prudential bank regulators and the Department of Justice initiated a program of aggressive enforcement against redlining by lenders of all types. Announced by Attorney General Merrick Garland in October 2021, the “Combatting […]
Read moreRegulatory Compliance has been an ever-evolving process for decades. But at least the changes have been mostly steady and slow. But during the last 15 years the pace of regulatory change has not only accelerated, but it’s also become a ping pong game among the last […]
Read moreThere’s a very big inconsistency in the Community Reinvestment Act. The current CRA rule was passed in 1995 and requires every FDIC insured bank to meet the credit needs of the communities they serve. All “covered” banks are subject to CRA performance evaluations every 3-5 years. […]
Read moreA milestone discussion on the past, present, and future of the Community Reinvestment Act A Historic Milestone Meets a Historic Expert For our landmark 100th episode of the Compliance 9-1-1 Show, hosts Dean Stockford of M&M Consulting and Len Susio of Geodata Vision knew they needed […]
Read moreThe Trump Administration officially has announced it intends to emphasize “deregulation” with a focus of eliminating 10 regulations for every new regulation. Eliminating regulations is one thing, but enforcement is another matter. Roy Cohn, who advised Trump early in his business career, once said, “Don’t tell […]
Read moreBank regulators have announced their intention to repeal the 2023 CRA Rule. But it would be a mistake to stop there. For more than a decade there’s been a clamoring to “modernize” the CRA regulations. If the Administration should merely rescind the 2023 rule it would […]
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