New Developments in Community Reinvestment Act Regulation and Examination
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1 New Developments in Community Reinvestment Act Regulation and Examination Northwest Compliance Conference Seattle, WA October 6, 2016 Legal Counsel to the Financial Services Industry Presented by: Warren W. Traiger Senior Counsel New York City 1
2 Revisions to the CRA Q & As Service Test Branches still key but alternative delivery systems get a shoutout: ATMs Online and Mobile Other means that evolve over time Non-branch delivery systems must be available and effective : Ease of access Cost benefit Rate of use Reliability 2
3 Revisions to the CRA Q & As Innovative and Flexible Loans, Investments and Services Reiterates that innovative, flexible and complex practices can augment a bank s CRA performance but are not required for an outstanding or satisfactory rating New examples of innovative practices: Outreach initiatives or financial counseling in connection with small dollar loan programs that are made in a safe and sound manner with reasonable terms Use of alternative credit history (e.g., utility or rent payments) to supplement traditional underwriting 3
4 Revisions to the CRA Q & As Community Development Clarifications Promoting Economic Development Examiner flexibility in reviewing information provided by bank Emphasis on workforce development and technical assistance to small businesses Presumption in favor of loans or investment in CDFIs that finance small businesses or farms Revitalizing or Stabilizing Underserved Nonmetropolitan Middle- Income Communities Communications infrastructure as essential community service Community Development Lending Consideration for loans financing renewable energy facilities or NOTE: energy-efficient improvements in affordable housing Examples of CD activities in Q & As are not intended to be exhaustive and an activity listed only as an example for a CD loan, investment or service is relevant to all three. 4
5 The CRA: Not a Fair Lending Law? There is no mention of prohibited bases or protected classes in the CRA It only addresses bank service to individuals and neighborhoods of different income levels BUT, an ill-delineated assessment area may impact an institution s CRA rating, as well as raise concerns about redlining and disparate treatment 5
6 The CRA: Not a Fair Lending Law? The Interagency Fair Lending Examination Guidelines direct examiners to use the bank s CRA compliance record in their comparative analysis for redlining: Identify and delineate any areas within the institution s CRA assessment area and reasonably expected market area for residential products that are of a racial or national origin minority character Review prior CRA lending test analyses to learn whether they have identified any excluded or otherwise under-served areas or other significant geographical disparities in the institution s lending. Determine whether any of those are minority areas 6
7 The CRA: Not a Fair Lending Law? The evaluation of a bank s CRA performance is adversely affected by evidence of discriminatory or other illegal credit practices including, but not limited to: Discrimination on a prohibited basis in violation of the Equal Credit Opportunity Act or the Fair Housing Act Violations of the Home Ownership and Equity Protection Act Violations of section 5 of the Federal Trade Commission Act Violations of section 8 of the Real Estate Settlement Procedures Act Violations of the Truth-in-Lending Act provisions regarding a consumer's right of rescission 7
8 The CRA: Not a Fair Lending Law? The impact of discriminatory or other illegal credit practices on a bank s CRA rating depends on: The nature, extent, and strength of the evidence of the practices The policies and procedures that the institution has in place to prevent the practices Any corrective action the institution has taken, or has committed to take, including voluntary corrective action resulting from self-assessment Any other relevant information, including training program Evidence of illegal credit practices generally results in a single rating downgrade, but a double downgrade is not unprecedented 8
9 CRA: What s Next? Regulatory Reform: Agencies continue to consider 2010 comments and testimony solicited on modernizing the CRA rules in areas including the following: Assessment area delineation: Delineate assessment areas based on where a bank does business, instead of on the physical locations of a bank s branches and deposittaking ATMs reiterated this year by Comptroller Curry Performance tests: For large banks, substitute a separate community development test for the existing investment test and the community development components of the lending and investment tests 9
10 CRA: What s Next? Affiliate activity: Routinely consider affiliate lending activities in CRA evaluations, instead of allowing banks to decide whether affiliate activity should be considered Loan purchases: Devalue or eliminate credit for loan purchases or assess whether purchases provide liquidity to marketplace, instead of providing equivalent CRA consideration for all loan purchases and originations Fin Tech Issues OCC encouraging responsible innovation that provides fair access to financial services and fair treatment of consumers 10
11 Questions Warren W. Traiger, Senior Counsel buckleysandler.com infobytesblog.com 11
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Welcome to Fair Lending Practices Extending credit is a cornerstone of banking. Because of the need society has for lending and credit, Congress has passed a number of acts ensuring that banks distribute
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