On May 5, the FDIC released a list of state non-member banks evaluated for compliance with the CRA during February 2025. Under the CRA, the FDIC assesses how effectively banks meet the credit needs of their entire community,...more
On May 1, the OCC released its CRA performance evaluations that became public during the month of April. The OCC evaluated 26 entities, including national banks, federal savings associations, and insured federal branches of...more
In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I...more
In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more
On March 3, the OCC released its CRA performance evaluations that became public during the month of November. The OCC evaluated 26 entities, including national banks, federal savings associations, and insured federal branches...more
On February 2, the OCC released its CRA performance evaluations that became public during the month of January. The OCC evaluated 20 entities, including national banks, federal savings associations, and insured federal...more
On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...more
Consistent with recent indications from CFPB and Department of Justice officials that more redlining cases would soon be coming, the CFPB and DOJ have announced a proposed consent order with Hudson City Savings Bank to settle...more
Many big cities in the United States responded to the fallout from the 2008 financial crisis by passing local laws which pressure banks to invest more in low-income neighborhoods. Between 2010 and 2013, cities such as New...more
This week, the Ferguson Commission released an analysis of the socio-economic environment following the shooting of Michael Brown that included recommendations for financially strengthening lower-income areas. The Commission,...more
On August 15, 2015, the CFPB released its latest “consumer complaint snapshot.” The Bureau’s “snapshots” generally provide updated national complaint information, and further include product and geographic spotlights that...more