I’ve written articles critical of the Section 1071 Rule and the CFPB’s implementation of the new rule. For example, the scheduled “applicable dates” for data recording and reporting make no sense at all. As currently...more
9/6/2024
/ Borrowers ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Section 1071 ,
Small Business Loans
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
8/27/2024
/ Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Redlining ,
Regulatory Requirements
In a recent podcast, Len and Dean discuss the June 10 article "Manufacturing Fair Lending" from National Mortgage Professional, which delves into the "Modern Theory of Redlining" introduced by bank regulators after AG...more
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
7/25/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining ,
Risk Management
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
6/17/2024
/ Banks ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
In this podcast episode, Dean and Len discuss the timely issue of appraisal discrimination and bias within the context of Fair Lending. Dean highlights the FFIEC's recent guidance on mitigating risks related to discriminatory...more
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
6/13/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
Since October 2021, the prudential bank regulators in concert with the Department of Justice have been pursuing the “Anti-Redlining Initiative” announced by Attorney General Merrick Garland on October 21, 2021. During that...more
5/20/2024
/ Banks ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
FFIEC ,
Financial Services Industry ,
HMDA ,
Mortgages ,
Race Discrimination ,
Redlining
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
2/26/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
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
1/18/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining