Margaret Dolinger

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

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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Submit Comments to CRA Modernization Initiative

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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personal data

Amid Data Reporting Uncertainty, HMDA Risk Must Be Managed: Part 1—How is it Going?

Now that more than half the year is gone, many banks are starting to look more closely at their new 2018 HMDA LAR requirements because they have adequate volume to do testing. TCA wants to share with you what we have found in doing preliminary HMDA LAR validations. Many of the issues we’ve seen are

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fair with wooden blocks

The Expectation of Exceptions in the World of Fair Lending

Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want

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corporate social responsibility

CRA Celebrated its 40th Year—Look for Greater Emphasis on Community Development Efforts

The Community Reinvestment Act (CRA) celebrated its 40th anniversary in 2017. The Act was established to ensure banks were meeting the credit needs of the community they designated as their assessment or market area, which often was a circle around their branches. Passing a CRA exam was less troublesome since bankers only had to be

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