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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As lenders face increasing scrutiny from the regulatory and enforcement agencies with regard to fair lending in general, and redlining in particular, institutions are searching for ways to mitigate these risks. Why Correcting a Problem is So Hard Fair lending risk management now demands a data-centered strategy, as the focal point of a redlining examination, […]
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As we move out of the holiday season and prepare for the new year, we wanted to take a moment and remind you of (4) HIGHLY critical issues at our doorsteps affecting lending compliance. We provide a brief summary of each of these with associated Action Items. Evaluation of the Impact of 2020 Census Changes […]
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You are no doubt aware of the significant changes with the implementation of the Current Expected Credit Loss (CECL) accounting standard. CECL represents a major shift in the way that financial institutions have historically estimated and set aside funds for credit losses on loans and other financial instruments. The evolving regulatory scrutiny associated with these […]
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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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