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…
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. One important aspect of…
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…
In light of recent news regarding Bank of America’s penalties for inaccurate reporting under the Home Mortgage Disclosure Act (HMDA), it’s evident that precise reporting and adherence to HMDA regulations are paramount. Leveraging advanced HMDA analytical software empowers lenders to take proactive steps toward compliance and avoid similar pitfalls. The Significance of Government Monitoring Information…
In recent years, the U.S. federal government has taken concrete steps to clamp down on redlining — the illegal practice of denying services to residents of certain areas based on racial or ethnic composition. The Combatting Redlining Initiative reflects a groundswell of regulatory actions intended to root out these discriminatory practices in the housing and…
In life it’s a common adage that “an ounce of prevention is worth a pound of cure.” Nowhere is this wisdom more evident than in the realm of fair lending compliance practices. For banks and financial institutions, compliance with fair lending laws is a financial imperative. Redlining, the practice of denying financial services to certain…
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…