Fair Lending and Community Reinvestment Act (CRA) Training
Join us for this new program led by Patti Joyner for the opportunity to focus in on:
Fair Lending
- Continued Focus on Redlining: Geographic Lending Patterns
- Enforcement Actions Insights
- Equal Credit Opportunity Act (ECOA)
- Applicability – Applicants vs. Pre-Applicant
- Prohibited Bases of Discrimination
- Focus on Adverse Action Notices
- Housing Agencies’ Fair Lending Oversight
- AB 2023-05: Enterprise Fair Lending and Fair Housing Rating System
- Appraisal Bias and Reconsiderations of Value (ROV)
- Appraisal Discrimination: Application of the Fair Housing Act and Risk Mitigation
- Fair Lending and Consumer Risks in Artificial Intelligence (AI) and Machine Learning (ML)
- Interagency Guidance
- Lessons from Lawsuits
Community Reinvestment Act (CRA) Modernization
- CRA Examination Categories
- Large Banks (assets $2 billion or more in assets)
- Retail Lending Test,
- Retail Services and Products Test,
- Community Development Financing Test, and
- Community Development Services Test.
- Intermediate Banks (assets of at least $600 million and less than $2 billion) will be evaluated under the
- New Retail Lending Test and
- Either the current Intermediate Bank Community Development Test, or, optionally, the new Community Development Financing Test.
- Small Banks (assets of less than $600 million)
- Current Small Bank Lending Test or, optionally, the new Retail Lending Test.
- Limited Purpose Banks (including wholesale banks)
- A modified Community Development Financing Test for Limited Purpose Banks
- Banks of all sizes can still request an evaluation under an approved Strategic Plan.
- Large Banks (assets $2 billion or more in assets)
- Geographic Assessment Focus
- Facilities-Based Assessment Area
- Retail Lending Assessment Areas
- Outside Retail Lending Area
- CRA Examination Tests
- Retail Lending Test
- Retail Services and Products Test
- Community Development Financing Test
- Community Development Services Test
- Performance Test and Overall Performance Ratings
- Impact of discriminatory or illegal credit practices
- Eleven Community Development Categories
- Data Collection and Reporting