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CFPB Discusses Enforcement Work and What Lies Ahead in 2024

Summary The conversation discusses the recent article from the CFPB on their enforcement work in 2023 and what lies ahead. The main themes include the emphasis on enforcement and the use of technology by the CFPB, the potential game-changing impact of technology in data analysis, and the importance of third-party support in analyzing data. The […]

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8 Key Takeaways From 1Q2024 Patriot Bank and First National Bank of Pennsylvania Enforcement Actions

As promised, the Department of Justice continues to pursue enforcement actions against lenders for allegations of redlining. Two of the latest are Patriot Bank, announced January 19th, and First National Bank of Pennsylvania, announced February 5th. Of note, in the case of Patriot Bank, this is the 3rd redlining enforcement action pursued by Justice within […]

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Bank Data: It’s a Numbers Game

While technological advances have increased efficiency and, in some ways, made things easier, these advances have also increased the speed at which things move and created more demands. One of these demands is the need to analyze ever-increasing quantities of data. This data contains potential risks and potential rewards for financial institutions. It contains risks […]

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Analysis of Bank Failures Reveals Unexpected Risks

On May 1, 2023, First Republic Bank (FRB), headquartered in San Francisco, became the third bank to fail this year. Silicon Valley Bank (SVB) and Signature Bank failed earlier this year; and Silvergate Bank, which was closely tied to the U.S. crypto economy, liquidated itself and is not listed by the FDIC as a bank […]

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HMDA 2022: Increased Minority Lending and the Rate Environment

In a recent post we highlighted the increases in aggregate HMDA lending between 2021 and 2022 in majority-minority census tracts (MMCT’s) as reflected in the preliminary public HMDA data recently released by the CFPB.  Of the 412 Metropolitan Statistical Areas (MSA’s) as designated by the Office of Management and Budget (OMB), 75% reflected at least […]

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Rate Environment Has Consequences for Credit Quality

Credit conditions have changed rapidly and have created a situation for lenders which is very different than just a few years ago. As an illustration, consider the historical prime loan rate as shown in Figure 1. After years of volatility, the prime rate fell to an historically low 3.25 percent in the middle of the […]

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1071 Small Business Reporting Fair Lending Fact Sheet

The upcoming reporting of small business lending under the 1071 section of the Dodd-Frank Act imposes additional compliance and fair lending burdens on banks and other lending institutions.  The compliance aspects include data collection, reporting, and complying with the requirements; and the fair lending implications include the impact of these data with respect to fair […]

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MSAs Post Big Swings in Majority-Minority Census Tract Lending

The preliminary 2022 HMDA data recently released by the CFPB is the first glimpse into aggregate lending distributions geographically based on the new 2020 Decennial Census data. Lenders were required last year to begin reporting census tracts based on the new Census. This is the first public release of this lending data for 2022. From […]

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Two Critical Fair Lending Impacting Events Already Unfolding in 2023

Earlier this year, we highlighted 4 forthcoming critical events that banks should be ready for with regard to regulatory compliance risk. Things are moving quickly this year, with 2 of these already now in play.  These are (1) the availability of preliminary public HMDA data reported by institutions for calendar 2022 and (2) the release […]

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Large and Small Banks Must Have a Holistic Approach to Maintain Solvency

The U.S. Economy rose 2.6% in the fourth quarter according to the BEA’s third and final estimate released March 30th. This latest estimate marked a slight downward revision from the previous fourth quarter estimate of 2.7% and a deceleration from the third quarter growth of 3.2% growth. Despite the two quarters of back-to-back above trend […]

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