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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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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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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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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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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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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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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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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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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As we move out of the holiday season and prepare for the new year, we wanted to take a moment and remind you of (4) HIGHLY critical issues at our doorsteps affecting lending compliance. We provide a brief summary of each of these with associated Action Items. Evaluation of the Impact of 2020 Census Changes […]
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