As we are all aware by now the Final Rule for the 1071 Small Business Data Collection was issued March 30, 2023. Many financial institutions are questioning where and how to start the process of identifying the small business loans to be counted. The final rule provides three methods to determine if a small business …
By Margaret Dolinger, CRCM 1071 Dodd Frank requires financial institutions to collect data on small business loans and record them on a Small Business Lending Application Register. The Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule on October 8, 2021, regarding the covered institutions and covered transaction pursuant to proposed Regulation B 1002.101 – …
Small Business Data Collection – Are You Having the Conversation? Read More »
Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated …
The 2020 Census data has been released by the US Census – and it may impact your Assessment Area for CRA and your Lending Area for Fair Lending. The Federal Financial Institutions Examination Council (FFIEC) which provides uniformity and consistency in the supervision of financial institutions, incorporates the US Census data in a format that …
2022 Census Tracts Changes What it May Mean for Your Assessment Area Read More »
On April 26, 2022, Wolters Kluwer conducted a webinar “Special Purpose Credit Programs: Everything You Always Wanted to Know”. The speakers included: Patrice Ficklin, Fair Lending Director of the Consumer Financial Protection Bureau Pamela Perry, Vice President, Single-Family Equitable Housing, Freddie Mac Kenneth Scott, Citibank Anand Raman, Skadden Arps The speakers discussed the credit needs …
A Refresh on Regulation B’s Special Purpose Credit Program Read More »
The Consumer Financial Protection Bureau (CFPB) announced on March 16, 2022, the added scrutiny of illegal discriminatory practices within its examination procedures for Unfair, Deceptive, Abusive Acts and Practices (UDAAP). The CFPB considers that illegal discrimination practices based on services or products can cause consumer harm; therefore, UDAAP should be included with the other Fair …
CFPB’s UDAAP Is Seriously Looking for Illegal Discrimination Practices Read More »
The OCC issued News Release 2021-133 on December 14, 2021, announcing the final rescinding of their June 2020 Community Reinvestment Act (CRA) Rule. The Final Rule will become effective as of January 1, 2022 and will apply to all national banks as well as to both federal and state savings associations. Financial institutions regulated by …
Everything Old is New Again- OCC Rescinds CRA Rules Read More »
Answer: Yes. The Financial Institution needs to be aware of what makes up the data that is obtained and how the data is applied. These algorithms may be filtered by zip codes, level of education or purchasing behaviors. The Financial Institution needs to ensure the algorithms used do not cause disparate impact by eliminating protected …
When: August 17, 2021 10am – 11:30 am CST Fair lending continues to be a hot topic for all lending institutions. Understand the fair lending risk factors that the regulators are focusing on such as redlining, disparate impact, fair lending monitoring, pricing exceptions, underwriting exceptions, and marketing. Know the importance of understanding your lending pattern …
For those of you regulated by the OCC and trying to plan the implementation of the June 2020 final CRA rule – Look Out! In OCC Bulletin 2021-24, issued May 18, 2021, the OCC stated that it will “Reconsider” the CRA Final Rule. Yes, you read that correctly. As many financial institutions and software vendors …
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