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Mortgages Financial Institutions Fair Lending

The term "mortgage" typically refers to a mortgage loan.  A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and... more +
The term "mortgage" typically refers to a mortgage loan.  A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and uses that property as collateral for the loan. less -
Troutman Pepper

DOJ Reaches Historic Multi-Million Dollar Redlining Settlement With Citadel Federal Credit Union

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On October 10, the U.S. Department of Justice (DOJ) announced a landmark redlining settlement with Citadel Federal Credit Union (Citadel), marking the first such agreement with a credit union in the DOJ’s history. This...more

Ballard Spahr LLP

Citadel FCU is first credit union to settle DOJ redlining complaint

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The Justice Department announced that Citadel Federal Credit Union has agreed to pay more than $6.5 million to resolve allegations that it engaged in a pattern or practice of redlining majority-Black and Hispanic...more

GeoDataVision

The new Community Reinvestment Act Omits Critical Types of Credit That Meet Community Needs

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Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule.  But perhaps their frustration should be focused on the regulators who have...more

GeoDataVision

Is Fair Lending Enforcement Fair Today? Part II

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Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is called a “REMA” or...more

GeoDataVision

How to Minimize Compliance Risk in the Radical New “Modern” Redlining Era

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As any bank professional regulatory compliance professional knows redlining is the hottest issue today and has been since Attorney General Merrick Garland announced the “Combatting Redlining Initiative” in October 2021. Since...more

GeoDataVision

“Manufactured” Redlining

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In a recent article in National Mortgage Professional entitled "Manufacturing Fair Lending”, former chief of the Housing and Civil Enforcement Section at the Department of Justice under Attorney General William Barr, Paul...more

GeoDataVision

“Figures don’t lie” but do regulators figure? Simpson’s Paradox says so

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In emails in recent months we've warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ....more

GeoDataVision

Is Fair Lending Enforcement Fair Today?

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Every banker should know by now that the Department of Justice announced an “Anti-Redlining” crusade in October 2021. In his October 2021, press release, Attorney General Merrick Garland, proclaimed that redlining is...more

Troutman Pepper

DOJ Comments Reveal Road Ahead for Mortgage Redlining

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For the last two years, the federal regulatory agencies have been waging a war on redlining by mortgage lenders — a war that shows no signs of abating. Originally published in Law360 - December 12, 2023....more

GeoDataVision

The Potentially Adverse Fair Lending Implications of the New CRA Rule

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There has been much understandable handwringing about the new CRA and its complexity as well as the high CRA exam failure rate predicted by regulators based on the new assessment areas and the higher performance standards...more

GeoDataVision

The new CRA: Surprises and Problems by Omission

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I have written a number of articles about the new CRA and the problems its requirements will impose on banks. But there are also problems posed by what the new Rule omits....more

GeoDataVision

What is a “REMA” and why is it so important?

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As I write this article the Department of Justice is pursuing a record-breaking number of “redlining” cases against banks and mortgage lenders. The “Anti-redlining Initiative” was announced October 22, 2021, by Attorney...more

Orrick, Herrington & Sutcliffe LLP

NYDFS releases guidance on risk management

On December 21, 2023, NYDFS released guidance for managing significant financial and operational risks associated with climate change for New York State-regulated banking and mortgage institutions. The guidance emphasized the...more

Ballard Spahr LLP

CFPB Language Access Plan for Consumers with Limited English Proficiency

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Throughout the past few years, the CFPB has sought input from a range of stakeholders, including community-based organizations and financial institutions, for feedback about how it can improve consumer financial products and...more

Jenner & Block

CFPB and other Federal Regulators Eye Regulation Aimed at Curbing Algorithmic Bias in Automated Home Valuations

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Late last month, the Consumer Financial Protection Bureau (CFPB) took another step toward adopting rules governing the use of artificial intelligence (AI) and algorithms in appraising home values. Specifically, the CFPB...more

Bilzin Sumberg

An Opportune Time For Financial Institutions to Review Their Fair Lending Procedures

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At the beginning of his term, President Biden declared that his administration would make it a policy to eliminate “racial bias and other forms of discrimination in all states of home-buying and renting.”...more

Ballard Spahr LLP

CFPB Summer 2021 Supervisory Highlights looks at auto servicing, consumer reporting, debt collection, deposits, fair lending,...

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The CFPB has released the Summer 2021 edition of its Supervisory Highlights. The report, which contains 48 pages of supervisory observations, discusses the Bureau’s examinations in the areas of auto servicing, consumer...more

Hinshaw & Culbertson - Consumer Crossroads

Following Fair Lending Investigation, NYS DFS Issues Report, Recommendations, and Mortgage Lender Best Practices

The New York State Department of Financial Services (DFS) issued a report on February 4, 2021, detailing its investigation of the mortgage lending market in the Buffalo metropolitan area. The report includes findings about a...more

Ballard Spahr LLP

CFPB identifies 2017 priorities in annual fair lending report

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In its new annual report covering its fair lending activities during 2016, the CFPB identifies the following three areas on which it “will increase our focus” in 2017...more

Ballard Spahr LLP

PLI 22nd Annual Consumer Financial Services Institute, Chicago session – 25% discount available

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The second presentation of the 22nd Annual Consumer Financial Services Institute, sponsored by the Practising Law Institute, will take place in Chicago on May 4-5, 2017. I am co-chairing the event, as I have for the past 21...more

McGuireWoods LLP

CFPB’s 2017 Fair Lending Priorities

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At the end of last year, the CFPB issued its Fair Lending Priorities for 2017. According to its December blog post, the CFPB plans to increase its focus on the following three areas, which it describes as “presenting a...more

Ballard Spahr LLP

CFPB announces 2017 fair lending priorities

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In a blog post published last Friday, Patrice Ficklin, Associate Director of the CFPB’s Office of Fair Lending, outlined the CFPB’s fair lending priorities for 2017. Ms. Ficklin wrote that, going forward, the CFPB will...more

Ballard Spahr LLP

CFPB issues Fall 2016 Supervisory Highlights

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In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more

Ballard Spahr LLP

CFPB issues Summer 2016 Supervisory Highlights

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In its Summer 2016 Supervisory Highlights, which covers supervision work generally completed between January and April 2016, the CFPB highlights violations found by its examiners involving automobile origination, debt...more

Ballard Spahr LLP

CFPB issues 2015 fair lending report

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The CFPB has issued a report covering its fair lending activities during 2015.  The report states that in 2015, CFPB fair lending supervisory and public enforcement actions required institutions to provide approximately $108...more

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