Margaret Dolinger, Author at TCA

Meet your Community’s Credit Needs for Fair Lending – Utilizing Regulation B’s Special Purpose Credit Program

“What are you doing to ensure diversity, equity and inclusion (DEI)?” That question routinely comes up during conference calls among us, clients, and regulatory agencies. Businesses, educational institutions, and non-profit organizations all are focusing on DEI. Financial institutions are no exception. In fact, regulatory agencies emphasize the importance of DEI in written communications about the Fair […]

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No Longer A HMDA Reporter – Fair Lending Still Applies

Compliance IQ / By Margaret Dolinger

On April 16, 2020, The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds in Regulation C for financial institutions reporting data under the Home Mortgage Reporting Act (HMDA). A permanent threshold for collecting closed end mortgage reporting data went from 25 to 100 loans effective July 1, 2020. Also, open-end

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OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet?

Fair Lending/CRA, Special Release / By David Mulkerin, Margaret Dolinger

If your institution is regulated by the FDIC or FRB, you can stop reading here, unless you want to see what could be coming your way in the near future. The OCC published a final Community Reinvestment Act rule on June 5, 2020 which marks a departure from the OCC, FDIC and FRB being “in

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Three Hot CRA Concerns

Compliance IQ, Fair Lending/CRA / By Margaret Dolinger

Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs,

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Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!

Fair Lending/CRA, In Depth / By Margaret Dolinger

As we are all in this unusual time of a pandemic with various levels of lockdowns and social restrictions and the resulting economic downturn, unemployment and business closures, many financial institutions are trying to wade through processes on how to help their customer base through modifications, deferments, waiving of fees and loan proceeds for small

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Do These Activities Qualify for CRA Credits?

Fair Lending/CRA, In Depth / By Margaret Dolinger

COVID-19 has caused nationwide turmoil, including in the financial services industry. Banks have been flooded with inquiries regarding deferral of payments, modification of loan provisions and loan requests to keep businesses afloat. Many banks have asked TCA whether certain activities would be considered as CRA credits or qualified community development activities. The first of many

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Fair Lending – The Latest

In Depth / By Margaret Dolinger

Regardless of bank size, complexity or risk profile, there is a universal myth when it comes to Fair Lending that there has been less enforcement since 2016. The truth is that Fair lending is one of the top enforcement rules. TCA recently attended a Fair Lending conference that included a regulatory panel discussion focusing on

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hand touching regulation on computer screen

New MSA Codes, 2019 Demographic Changes and 2018 HMDA Aggregate Data

Special Delivery / By Margaret Dolinger

We’ve received a lot of inquiries on what happened with the 2019 MSA codes: When will the pending 2019 demographic information changes be released? Has the 2018 HMDA Aggregate Data been announced? This “Special Delivery” will provide the most current information available to these questions. New MSA Codes Confusion In April 2018, OMB Bulletin No.

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Fair Lending and Marketing in the Digital Age

In Depth / By Margaret Dolinger

There’s an old saying, “You don’t know what you don’t know” and that is certainly true when it comes to marketing initiatives meshing with the world of fair lending. The clash of both worlds and the often-divergent priorities have caused regulators to put this intersection under a microscope. A key fact today is that marketing

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Submit Comments to CRA Modernization Initiative

Fair Lending/CRA, Special Release / By Margaret Dolinger

Several staff members of Thomas Compliance Associates (TCA) attended the recent CRA & Fair Lending Colloquium and obtained valuable information from the sessions. One theme that stood out and presenters stressed was that bankers can help shape the re-write of the Community Reinvestment Act (CRA) regulation. The Office of the Comptroller of the Currency (OCC)

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Margaret Dolinger

Meet your Community’s Credit Needs for Fair Lending – Utilizing Regulation B’s Special Purpose Credit Program

No Longer A HMDA Reporter – Fair Lending Still Applies

OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet?

Three Hot CRA Concerns

Loan Servicing & Loss Mitigation Are Fair Lending Risks Too!

Do These Activities Qualify for CRA Credits?

Fair Lending – The Latest

New MSA Codes, 2019 Demographic Changes and 2018 HMDA Aggregate Data

Fair Lending and Marketing in the Digital Age

Submit Comments to CRA Modernization Initiative

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