Author: Premier Insights

Articles by: Premier Insights

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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Critical Preliminary 2022 HMDA Data Now Publicly Available

This week the CFPB released preliminary HMDA data for all lenders reported for calendar year 2022. These data are routinely updated each year after financial institutions have done their annual submission, which are due March 1st of each year. Although this release is an annual event, and has been taking place for decades, this year’s […]

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The Critical Role of Regulatory Forensics

The regulatory world in which financial companies operate is a vast sea of uncertainty that is seemingly in a constant state of churn. Although the laws and regulations themselves are not necessarily constantly changing, regulatory interpretation and shifting priorities, coupled with bifurcated and shifting agendas, create a sort of organized chaos.  This makes compliance difficult, […]

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On The Use of Regression Analysis in Fair Lending

In recent posts, we have focused on redlining as one of the more prominent fair lending risks that institutions are facing today. The agencies have clearly made redlining a top priority, and recent fair lending enforcement actions have confirmed this. There is, however, more to the fair lending risk management story. The Many Facets of […]

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Special Purpose Credit Programs: Are They Right For Your Institution?

As lenders face increasing scrutiny from the regulatory and enforcement agencies with regard to fair lending in general, and redlining in particular, institutions are searching for ways to mitigate these risks.  Why Correcting a Problem is So Hard Fair lending risk management now demands a data-centered strategy, as the focal point of a redlining examination, […]

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Fair Lending Redlining: The Nuances and Challenges of Detecting and Correcting Problems

In our previous post on the topic of redlining, we discussed how redlining is an issue that can have serious consequences for banks that do not adequately manage these risks. However, detecting and correcting redlining issues can be complex and nuanced, which is why it’s important to be proactive in addressing these and other fair […]

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The Role of Fair Lending Risk Assessments in Banking Compliance

Financial institutions are under constant and increasing scrutiny from regulators to manage fair lending risk and ensure compliance with fair lending laws. In this context, conducting fair lending risk assessments is paramount for risk managers who are aiming to not only meet legal requirements, but also promote positive customer outcomes and avoid appearances of practices […]

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