In previous posts (see The Fair Lending Risk of Good Intentions) we have discussed fair lending risks associated with certain well-intended practices. In an effort to avoid fair lending risks, institutions may find it tempting to have practices that either favor protected classes or policies that eliminate any variation in pricing or decisioning in an […]
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2020? Yes, 2020. With the bizarre nature of last year, it is easy to overlook some of the year’s significance. One is that 2020 was a Decennial Census year, with the population of the U.S. recounted. It is never too early to think about this as there will likely be changes that will affect those […]
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Between Covid-19, multiple hurricanes, social unrest, and Murder Hornets, the year 2020 has been strange, if not bizarre, to say the least. The year has also been “interesting” when it comes to the economy. Today we will discuss where we are and what we might expect in the coming months. Defining Terms The National Bureau […]
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Fair lending concerns are one of the dominant risks lenders face in regard to their business operations. Although larger lenders typically have significant resources in place to mitigate these risks, and there has been an emphasis in the last decade on quantitative methods for fair lending evaluation, there remains a great deal of subjectivity in […]
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The banking industry is entering a new chapter as the use of technology shifts from optional to mandatory in order to remain relevant in the current global and economic environment. As of July 20, 2020, the FDIC has released a request for information as part of its initiative to promote the efficient and effective adoption […]
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Below, we provide a summary of the recently released 2019 HMDA data, and keys for understanding the importance of these data. The Basics Enacted by Congress in 1975, and implemented by Regulation C, the Home Mortgage Disclosure Act (HMDA) is considered “the most comprehensive, publicly available information on mortgage market activity.” Its purpose is to […]
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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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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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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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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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