Let’s recap what has happened in 2025 on three different fronts: HMDA, fair lending, and the Community Reinvestment Act (CRA). I count seven important developments, listed in no particular order. 1. The 2024 HMDA Snapshot data were released in July 2025. A couple of observations: 2. Evolving Landscape for Redlining Enforcement With the change in federal administration…
The latest look at top home purchase markets shows Texas leading in origination volume, but compliance professionals know those numbers tell only part of the story. A deeper dive into filtered HMDA data¹ reveals that market conditions vary widely across metros. For instance, Dallas-Fort Worth-Arlington TX MSA saw originations drop from 111,645 in 2021 to…
As we move through 2025, two major regulatory developments continue to evolve, namely the federal banking agencies’ Community Reinvestment Act (CRA) final rule and the CFPB’s Section 1071 small business lending data collection rule, both finalized in 2023. Both rules aimed to modernize oversight and promote fair lending practices. Each is now facing significant legal…
In today’s ever-evolving regulatory landscape, staying informed about the latest developments is crucial for lenders. In this blog, we provide an update on the current status of ongoing legal challenges surrounding Dodd-Frank Section 1071 and federal Community Reinvestment Act (“CRA”) regulations. Dodd-Frank Section 1071 Oral argument is scheduled for February 3, 2025 in the U.S.…
Let’s recap what has happened in 2024 on three different fronts: HMDA, fair lending, and CRA (the Community Reinvestment Act). I count six important developments. These are listed in no particular order below: 1. OMB released a new MSA list in 2023, which was incorporated by the FFIEC in 2024. Some new MSAs and Metropolitan…
Introduction: Why MSA/MD Reclassification Matters Metropolitan Statistical Area (MSA) and Metropolitan Division (MD) reclassifications are more than administrative changes—they are strategic opportunities that can dramatically reshape lending portfolios. For financial institutions, these shifts provide: In 2024, the Office of Management and Budget (OMB) redefined the boundaries of MSAs and MDs. This blog explores how these…
State of legal challenges to CFPB and Section 1071 rulemaking On May 16, 2024, the Supreme Court ruled in CFPB v. Community Financial Services Association of America (also known as the Community Financial case) that the CFPB’s funding mechanism is constitutional under the Appropriations Clause in the Constitution. What does this have to do with…
The 2023 Modified HMDA LARs have been unveiled, offering a sneak peek into last year’s mortgage market’s performance. While it’s no secret that mortgage lending took a nosedive compared to the red-hot 2021, let’s dive into the nitty-gritty details using the powerful LendingPatterns™ HMDA analysis software and see what insights we can uncover. The Big…
Let’s recap what has happened in 2023 on three different fronts: HMDA, fair lending, and CRA (the Community Reinvestment Act). I count eight important developments. These are listed in no particular order below: 1. OMB released a new MSA list in July 2023, which will be incorporated by FFIEC in 2024. 2. The 2022 HMDA…
It’s now been five years since the HMDA reporting requirements were dramatically expanded in 2018, and, in my assessment, there continue to be substantial data quality concerns. In this blog, I will focus specifically on one field, the debt-to-income (DTI) ratio, which seems to be a source of perpetual headaches for reporting institutions. What are…