On June 18, 2025, the CFPB published its 2025 Section 1071 Interim Final Rule. Lenders covered by the 2024 Section 1071 Interim Final Rule should know what the 2025 Rule is changing, how it affects them and what they can and should do. Who is affected […]
Read moreEver 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 domain and is transparent and free. For example, the FFIEC […]
Read moreNow 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its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule.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 intimidating, and it excluded certain critical types of credit needed […]
Read moreBanks play a pivotal role in the economic wellbeing of our nation and local communities. Banks do this by being “financial intermediaries” facilitating the flow of funds between savers and borrowers. This obligation is so important that Congress passed legislation mandating that banks be periodically examined […]
Read morePresident Trump signed Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy on April 23, 2025”. The EO proclaims a policy goal of eliminating “the use of disparate-impact liability in all contexts to the maximum degree possible’”. Given the relatively long history of the application of […]
Read moreJust when you thought the flurry of executive orders pertaining to “deregulation” might have slowed down, the President signed, on April 23, 2025, Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy.” The EO proclaims a policy goal of eliminating “the use of disparate-impact liability in […]
Read moreIn the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I put forward another 3 potential improvements […]
Read moreIn 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 Rulemaking regarding the repeal […]
Read moreIn 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 areas mandated in the 2023 rule 2. The elimination of some very important […]
Read moreFill in your details to watch now. In this webinar, we will take an in-depth look at why the 2023 CRA Rule is detrimental to all communities, including underserved areas. Rather than improving the CRA, the rule introduced serious flaws that undermine its effectiveness as a […]
Read moreWhen the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices, significantly fix the flaws or repeal […]
Read moreToday, March 28, the regulators announced what many have been anticipating. The Agencies issued a press release indicating they intend to rescind the 2023 CRA rule. This is a good thing because the 2023 CRA rule was filled with some very bad ideas, including unrealistic assessment […]
Read moreEarlier today, 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 realized that the rescission hasn’t been […]
Read moreDear 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 the confusion. Numerous natural weather events have caused FEMA to issue declarations for […]
Read moreWhen the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is scheduled to become “applicable” January 1, […]
Read moreAs all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The new size categories apply for the year 2025. Really […]
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Read moreSamplesHMDA Market Data 2023CRA Market Data 2022Tract Income Class Map 2024Tract Minority Status Map 2024MSA Map 2024 SamplesNational Community Development Report – By StateNational CRA Small Business Market Report – By CountyNational HMDA Mortgage Market Report – By CountyNew CRA Demographic Benchmark Report- By State & […]
Read moreThese special reports have been developed by GeoDataVision to help banks estimate if their performance during 2023 would have been rated at least as satisfactory under the Retail Lending Tests (“RLT”). The RLT uses a combination of market data reported under HMDA and CRA (sometimes inaccurately called […]
Read moreDear Banker, On December 19, 2024 the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The new size categories will apply for the year 2025. Banks that qualify as Intermediate-small […]
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