In a recent post we highlighted the increases in aggregate HMDA lending between 2021 and 2022 in majority-minority census tracts (MMCT’s) as reflected in the preliminary public HMDA data recently released by the CFPB. Of the 412 Metropolitan Statistical Areas (MSA’s) as designated by the Office of Management and Budget (OMB), 75% reflected at least […]
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Credit conditions have changed rapidly and have created a situation for lenders which is very different than just a few years ago. As an illustration, consider the historical prime loan rate as shown in Figure 1. After years of volatility, the prime rate fell to an historically low 3.25 percent in the middle of the […]
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The upcoming reporting of small business lending under the 1071 section of the Dodd-Frank Act imposes additional compliance and fair lending burdens on banks and other lending institutions. The compliance aspects include data collection, reporting, and complying with the requirements; and the fair lending implications include the impact of these data with respect to fair […]
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The preliminary 2022 HMDA data recently released by the CFPB is the first glimpse into aggregate lending distributions geographically based on the new 2020 Decennial Census data. Lenders were required last year to begin reporting census tracts based on the new Census. This is the first public release of this lending data for 2022. From […]
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Earlier this year, we highlighted 4 forthcoming critical events that banks should be ready for with regard to regulatory compliance risk. Things are moving quickly this year, with 2 of these already now in play. These are (1) the availability of preliminary public HMDA data reported by institutions for calendar 2022 and (2) the release […]
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The U.S. Economy rose 2.6% in the fourth quarter according to the BEA’s third and final estimate released March 30th. This latest estimate marked a slight downward revision from the previous fourth quarter estimate of 2.7% and a deceleration from the third quarter growth of 3.2% growth. Despite the two quarters of back-to-back above trend […]
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This week the CFPB released preliminary HMDA data for all lenders reported for calendar year 2022. These data are routinely updated each year after financial institutions have done their annual submission, which are due March 1st of each year. Although this release is an annual event, and has been taking place for decades, this year’s […]
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In the first post in our series on AI in lending, I began a conversation with ChatGPT, a so-called “large language model” of AI that’s made headlines recently. In that first part of the discussion, we covered 3 major benefits of AI in lending. In our second post in the series, we discussed the major […]
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The regulatory world in which financial companies operate is a vast sea of uncertainty that is seemingly in a constant state of churn. Although the laws and regulations themselves are not necessarily constantly changing, regulatory interpretation and shifting priorities, coupled with bifurcated and shifting agendas, create a sort of organized chaos. This makes compliance difficult, […]
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In recent posts, we have focused on redlining as one of the more prominent fair lending risks that institutions are facing today. The agencies have clearly made redlining a top priority, and recent fair lending enforcement actions have confirmed this. There is, however, more to the fair lending risk management story. The Many Facets of […]
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