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…
Normally, when one thinks of the term “blind spot” our mind immediately goes to driving a car and what we can’t see in either our rear-view or side-view mirrors. What we cannot see is affected by our past driving experience, our vantage point or our location in the seat, the size/type of mirrors (tools to…
Regulatory compliance officers, fair banking officers, and fair lending analysts managers know the importance of complying with ever-changing rules. These include rules under the Home Mortgage Disclosure Act, the Community Reinvestment Act, the Equal Credit Opportunity Act (ECOA), the Fair Housing Act, and, Small Business 1071. However, juggling all of these areas seems impossible. The…
The announcement of the merger between Wings Financial Credit Union and ENT Credit Union on April 23, 2025, has prompted me to consider its impact on the industry, as well as what lenders can learn by examining the data behind the merger. The good news is that it is easy to create pseudo bank and…
The passage of the Community Reinvestment Act (CRA) in 1977 was a defining moment for fair lending practices in the United States. By encouraging banks to meet the credit needs of all segments of their local communities, including low- and moderate-income (LMI) neighborhoods, the CRA started the conversation about equitable access to financial services. The…
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…
geralt/ Pixabay Compliance with the Community Reinvestment Act (CRA) is essential for financial institutions that want to remain in good standing with regulators and the communities they serve. The CRA requires banks and other lenders to meet the credit needs of the communities in which they operate, particularly in low- and moderate-income areas. First enacted in 1977, the…
Federal regulators, including the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and National Credit Union Administration (NCUA), assess the strength of a bank’s Compliance Management System (CMS) during each examination. A strong CMS is essential for effective oversight, developing procedures, and continuous monitoring and auditing. Failure to maintain a…
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.…