The Final CRA Rule: Differences in the Proposed and the Final Rule

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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Making Sense of COVID-19 Numbers: 5 Keys to Data Interpretation

Making Sense of COVID-19 Numbers: 5 Keys to Data Interpretation

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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FFIEC Announces Release of 2019 Public HMDA Data & OCC Finalizes Community Reinvestment Act Rule

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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Challenges in Fair Lending Analysis, or Why You Don’t Have to Avoid Swimming Pools When Nicolas Cage is Working

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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CRA, The Regulatory Exam Process, & The Need For Change

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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CECL, Loan Losses, and the Pandemic

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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Highlights of 2018 Expanded HMDA Public Release

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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FDIC Initiates Efforts to Improve the Examination Experience

Regulatory exams are a way of life in the financial industry.  Institutions, especially commercial banks, face examinations on a regular basis from both federal and state agencies.  Examinations are generally divided into (2) categories: (a) compliance and (b) safety and soundness.  Although frequency varies with the type of examination, the regulatory agency, and the size […]

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Household Debt Surpasses Pre-Recession Levels

The financial crisis of over a decade ago is now behind us. For many, it is not much more than a distant memory. Although the causes and possible preventions have been theorized about and discussed extensively, and will be for future generations, there is no question that the underlying dynamic was the real estate asset […]

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CFPB Annual Fair Lending Report Addresses Small Business Lending

The Bureau of Consumer Financial Protection issued its seventh Fair Lending Report to Congress.  The report, released June 28, 2019, describes the Bureau’s fair lending activities in prioritization, supervision, enforcement, rulemaking, interagency coordination, and outreach for calendar year 2018.

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