Community Reinvestment

CBA is an acknowledged industry leader in the areas of Community Reinvestment, affordable lending, and community and economic development. As an association, through the Community Reinvestment Committee, CBA has significant influence in the development of revisions to CRA and amendments to the CRA Q&A, which interprets the regulations. One of CBA’s priorities is to encourage the agencies to maintain CRA as a sustainable business of banking, reflecting the reality of community development.
  • March 31, 2016
    On Thursday, March 31, 2016, Comptroller of the Currency Thomas Curry in a speech at Harvard Kennedy School's New Directions in Regulation Seminar released a long anticipated white paper entitled: "Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective." The white paper published the OCC's definition of responsible innovation, which is "[t]he use of new or improved...
  • March 22, 2016
    The CFPB issued an interim final rule on Tuesday, March 22, 2016, which broadened the availability of certain special provisions for small creditors operating in rural or underserved areas. The new rule, which takes effect March 31, 2016, implements the Helping Expand Lending Practices in Rural Communities (HELP) Act, which allows more small creditors operating in rural or underserved areas to...
  • March 18, 2016
    On Friday, March 18, 2016, Comptroller of the Currency Thomas Curry delivered remarks at the National Community Reinvestment Coalition (NCRC) conference where he addressed how national banks and federal savings associations can more effectively serve the credit needs of rural communities, especially those who are economically distressed. During his remarks, Comptroller Curry mentioned changes to...
  • March 4, 2016
    The FDIC issued, on Wednesday, March 2, 2015, a Financial Institution Letter clarifying its supervisory expectations in existing guidance for the risk-management practices when banks make the decision to discontinue foreclosure proceedings. “The FDIC continues to encourage institutions to avoid unnecessary foreclosures by working constructively with borrowers and considering prudent workout...
  • February 10, 2016
    Nearly eight years after the financial crisis, instances of misconduct across the spectrum of the industry continue to be reported in the press with troubling frequency. The coverage strikes an uncomfortable contrast with the intensity of effort the industry and the regulators have focused on reforming and remediating the weaknesses the crisis brought to light. Overall, this environment has...
  • February 9, 2016
    In his remarks at the National Interagency Community Reinvestment Conference on Tuesday, February 9, 2016, Comptroller of the Currency Thomas Curry indicated the OCC will release in the coming months a “Risk Management Guidance for Higher Loan-to-Value Lending in Communities Targeted for Revitalization.” This guidance is in response to concerns about barriers to financing homes and stabilizing...
  • January 12, 2016
    On Tuesday, January 12, 2016, the CFPB issued a construction loan factsheet providing an overview on how the TILA-RESPA Integrated Disclosure Rule (TRID) applies to these types of loans. At the outset, the Bureau expressly states TRID applies to most construction loans which are secured, closed-end consumer credit transactions. In contrast, open-end loans or those for a commercial purpose lie...
  • September 30, 2015
    September 30, 2015 Marketplace Lending RFI U.S. Department of the Treasury 1500 Pennsylvania Ave NW., Room 1325 Washington, DC 20220 Dear Sir or Madam, The American Bankers Association (ABA)1 and the Consumer Bankers Association (CBA)2 (together, the “Associations”) are pleased to provide the following comments to the United States Department of the Treasury (Treasury) in response to its request...
  • September 28, 2015
    If the court approves the settlement case, Hudson City Savings Bank have to pay $2.25 million for outreach and community programs, $5.5 million for penalties and $25 million to fund a subsidized program for black and Hispanic neighborhoods to have increased opportunities for mortgages. The bank said it does not agree with the loan statistical analysis but it agreed to give $25 million as...
  • August 7, 2015
    Another Constitutionality Challenge Filed Against the CFPB PHH Corporation on Friday, June 26, 2015 filed a Motion for Stay Pending Judicial Review with the D.C. Circuit Court of Appeals (Court) seeking to stay a final action of the CFPB scheduled to take effect on Wednesday, August 5, 2015. On Monday, August 3, 2015, the Court granted PHH's motion, finding the company had "satisfied the...

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