Margaret Dolinger

small business loan

Small Business Data Collection – Are You Having the Conversation?

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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 – […]

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HMDA News and Census Tract Updates

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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

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2022 Census Tracts Changes What it May Mean for Your Assessment Area

Compliance IQ / By

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

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A Refresh on Regulation B’s Special Purpose Credit Program

Compliance IQ / By

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

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UDAAP

CFPB’s UDAAP Is Seriously Looking for Illegal Discrimination Practices

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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

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community reinvestment act

Everything Old is New Again- OCC Rescinds CRA Rules

Fair Lending/CRA, Special Release / By

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

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Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms?

Fair Lending/CRA, Q&A / By

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

Are there fair lending concerns when a financial Institution utilizes a third-party vendor that provides data for marketing or assists in the development of a credit underwriting model containing digital algorithms? Read More »

Fair Lending

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

Compliance IQ / By

“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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