04/14/2024
If all of a lender's marketing is targeted outside the US, aside from marketing within its "claimed" assessment area, could the lender be subject to REMA redlining review?
I've read guidance that implies marketing doesn't have to be a factor for a REMA redlining exam to be conducted...
• "REMA...defines who and where you serve, and as such, is different from a defined Market Area..."
• "Where the lender actually marketed and provided credit, and where it could reasonably be expected to have marketed and provided credit based on its distribution of loans and applications "
• Redlining analysis will look at lending and level of services in majority-minority census tracts compared to peers, among other items.
10/01/2023
We are looking for a good product for recording and analyzing fair lending and CRA compliance. Are there any companies that we should be looking at? We understand BOL and the gurus can’t endorse any one product but would like to know what products the OCC and other regulatory agencies use as that would certainly be of interest. Is there any products not "recommended" but thought of highly?
07/30/2023
I was just made the banks CRA Officer. I know what CRA is but, I have no clue what the heck I am doing. What should I do first, second and third and for the long term?
05/16/2021
We relocated a branch. Based on the distance between both branches it was considered a relocation and not "closed." The question is, that if we must include that relocated branch in our CRA Public File as a closed branch?
10/18/2020
When reporting revenue on the small business LAR can you please clarify the following for me:
We have a loan program called "Low Doc" in which financials are not used in making the credit decision based on a number of factors, however we do have the revenue information from the customer. In order that these loans are not reported as a code 3 – and not counted in our CRA totals, is it appropriate in using the business revenues that the customer provided?
05/25/2015
What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.