Fair lending concerns are one of the dominant risks lenders face in regard to their business operations. Although larger lenders typically have significant resources in place to mitigate these risks, and there has been an emphasis in the last decade on quantitative methods for fair lending evaluation, there remains a great deal of subjectivity in […]
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The banking industry is entering a new chapter as the use of technology shifts from optional to mandatory in order to remain relevant in the current global and economic environment. As of July 20, 2020, the FDIC has released a request for information as part of its initiative to promote the efficient and effective adoption […]
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Below, we provide a summary of the recently released 2019 HMDA data, and keys for understanding the importance of these data. The Basics Enacted by Congress in 1975, and implemented by Regulation C, the Home Mortgage Disclosure Act (HMDA) is considered “the most comprehensive, publicly available information on mortgage market activity.” Its purpose is to […]
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As of May 20th, 2020, the Office of the Comptroller of the Currency has finalized a new rule to “strengthen and modernize” its regulations for the Community Reinvestment Act (“CRA”). This final rule is designed to “increase bank CRA-related lending, investment, and services in low- and moderate-income communities where there is significant need for credit, […]
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We have discussed in previous posts reliance on data and how technology and the instant access to information has been transformative in society. Technology and quick access to data continues to expand as does reliance on it. With such a deluge of various sources, both in terms of raw numbers and “processed” or interpreted information, […]
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2019 Public HMDA Data On Wednesday, the FFIEC announced availability of the 2019 public HMDA data: The Federal Financial Institutions Examination Council (FFIEC) today announced the availability of data on 2019 mortgage lending transactions at 5,508 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, […]
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The term “Information Age” probably pre-dates many who are reading this post, possibly originating as early as the 1970’s with the proliferation of computer technology. From the mainframe era, to PC’s, laptops, personal devices and smart phones, technology continues to shape our world at a seemingly ever increasing rate. This is all augmented by the […]
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On May 20th, FDIC Chairman Jelena McWilliams announced that the agency would not finalize the proposed rulemaking to modernize the Community Reinvestment Act at this time. The joint proposal also included the Office of the Comptroller of the Currency (OCC) support. The Federal Reserve has not signed on to the proposal. There was not a […]
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The Current Expected Credit Losses standards (CECL) have once again been delayed for an undetermined period of time due to the Coronavirus Pandemic. Despite CECL implementation being pushed down the road again, forecasting credit losses is again front and center. This stems from the uncertainty created by the Pandemic and the nation’s corresponding response. The […]
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The long awaited release of the expanded Home Mortgage Disclosure Act Loan Application Register (HMDA LAR) Data reported by filers in 2018 is now publicly available. These data contain elements that have not been reported by filers before, including critical loan decision attributes as well as specific data concerning loan pricing. In all, there are […]
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