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Financial Institutions Lending Banks

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

J.S. Held

Lending Climate in America – 3rd Quarter 2024 Survey

J.S. Held on

With inflation still affecting the US economy, lenders are now focused on the economic impact of the upcoming presidential election. Lenders’ expectations for the US economy’s performance in the longer term – beyond the next...more

Sheppard Mullin Richter & Hampton LLP

Persisting Regulatory Uncertainty: Federal Regulators Delay New Community Lending Rules

On March 21, the FDIC, Fed, and OCC jointly issued an interim final rule to extend the applicability date of certain provisions of the Community Reinvestment Act (CRA) final rule and requested comments on the extension. The...more

GeoDataVision

The Answers to the CRA Questions Everyone is asking: What must we do on April 1?

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With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers....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

The new CRA Rule: Confusion Reigns

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Our office has been inundated with inquiries about an aspect of the impact of the impending new CRA rule. As we have noted in previous articles there are mistakes and inconsistencies in the new CRA Rule, and some of these...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

GeoDataVision

The Disastrous New CRA Rule: Part IV – Is the 80% Retail Lending Assessment Area Exemption Really a Break for Large Banks?

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Dear Banker, The new CRA Rule contains a "break" for Large banks that would exempt them from having to declare Retail Lending Assessment Areas ("RLAAs") for any calendar year in which the bank lends more than 80% of its home...more

GeoDataVision

The Disastrous New CRA: Part III – It’s worse than you think and which banks are hurt the most

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In Parts I and II I explained the devastating impact of the new CRA Rule and what the underlying reasons for that adverse impact are. In Part III I will touch upon what banks are most significantly impacted by the new Rule....more

Ballard Spahr LLP

The New CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 3

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This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

GeoDataVision

New CRA Rule is a Disaster for Banks Part II: Key Regulator says Goal was “to raise the bar for CRA performance”

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In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new Rule demonstrate that if...more

GeoDataVision

New CRA Rule is a Disaster for Banks: Part I – And the Numbers Prove it!

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With all the news stories circulating about the new CRA Rule, it's surprising that not one article has addressed the topic that should be the biggest story of all - the catastrophic implications for banks!...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 2

Ballard Spahr LLP on

This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Proskauer Rose LLP

Insights on the NAV Lending Market

Proskauer Rose LLP on

We conducted an informal, small-scale survey during March to May 2023 to gather insights from prominent non-bank lenders on their activity over the past twelve months in the net asset value (NAV) lending market. In this...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 5, May 2023

Survey Finds Small-Business Lending Fraud on Rise - “Lending fraud with small and midsize businesses has increased significantly over the last 12 months, and many financial institutions expect it to get worse, according to...more

Bennett Jones LLP

Is Pricing All That Matters When Borrowing?

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For many borrowers, pricing is the most significant factor when deciding on a lender. If you are borrowing from a mid-market lender (MML), it is more than likely that the deal will be papered on that MML's standard form...more

Cadwalader, Wickersham & Taft LLP

Yellen Calls on World Bank to Take Decisive Action on Climate Change

On February 9, 2023, Treasury Secretary Janet Yellen spoke at the Center for Strategic and International Studies, urging the World Bank to “evolve” and be “bolder and more imaginative” in its operational approach to tackling...more

Guidepost Solutions LLC

Bank Merger Compliance Risks: Are You Prepared?

Bank mergers and acquisitions are becoming a regular part of life in the banking industry, especially for smaller and medium-sized organizations. They provide significant opportunities for institutions to expand their...more

Sheppard Mullin Richter & Hampton LLP

DFS Settles with Indirect Auto Lenders to Resolve Fair Lending Violations

On June 29, NYDFS announced that two New York-charted banks engaging in indirect auto lending will pay civil money penalties for violating New York’s fair lending law for engaging in practices that resulted in members of...more

Ballard Spahr LLP

The OCC’s CRA Final Rule: Changes And Highlights

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On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. This is the second in a series of five blog posts about the final rule....more

Manatt, Phelps & Phillips, LLP

OCC Moves Forward Alone, Issues Final Community Reinvestment Act Rule

On May 20, the OCC issued its final rule intended to modernize and clarify the Community Reinvestment Act (CRA). The rule included the surprising footnote that the FDIC, which had joined as a partner in the Notice of Proposed...more

Ballard Spahr LLP

OCC and FDIC issue joint proposal to revise CRA regulations

Ballard Spahr LLP on

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA).  Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join...more

Manatt, Phelps & Phillips, LLP

Short-Term Lending: Think Small, as OCC Nudges Banks

Not long after the CFPB’s acting director put the brakes on tough payday lending rules, the Trump administration likewise signaled that banks should move back into the $90 billion business....more

Locke Lord LLP

U.S. Treasury Department Requests Information on Online Marketplace Lending

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On Monday, July 20, 2015, the United States Treasury Department (UST) published a notice and request for information (RFI) in the Federal Register in order to request public comment on online marketplace lending. The RFI...more

Orrick, Herrington & Sutcliffe LLP

International Sovereign Bonds Issuance in Sub-Saharan Africa

The increasing dynamism of the Sub-Saharan African economy coupled with the continent’s large financing needs have led Sub- Saharan African countries to consider alternative sources of external funding to finance their local...more

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