With proposed changes to Community Reinvestment Act rules expected in late summer or early fall, we must remind federal regulatory agencies not to diminish the importance of home mortgage lending in CRA exams.
(Download) INTRODUCTION The Community Reinvestment Act (CRA) has leveraged trillions of dollars of loans, investments and services for low- and moderate-income (LMI) borrowers and communities. Since 1996, banks have made more than $1 trillion in community development loans, which finance affordable housing, economic development projects and community facilities for LMI communities. Likewise, banks have issued […]
Bank branches matter. Countering the overwhelming messaging from many banks and even some regulators, the National Community Reinvestment Coalition (NCRC) has published several reports over the years that detail how much branches still matter for consumers and communities, even in 2019. Just look at the number of branches that banks opened in the last year, and it is clear that they also know the value of a physical outpost in the community they want to serve.
In 2019, the total student loan debt in America is about $1.5 trillion. According to the New York Consumer Credit Panel, adults under 40 hold 65% of the total student loan debt. Although there has been much said about this figure, the income enhancement offered by a college degree still far outweighs the cost of the debt.
In September 2018, the Federal Deposit Insurance Corporation (FDIC) released the results of a survey of 1,200 banks on small business lending in America. It found that small business lending is threatened by the decline of smaller banks and the reduction of bank branches in many communities. But just as revealing was what the survey didn’t find. More information that would be essential for policy and regulatory decisions remains concealed, invisible to the public.
National Community Reinvestment Coalition (NCRC) President and CEO urged more lending and better service for low- and moderate-income communities (LMI) in remarks they made at two recent hearings on the proposed merger between BB&T Bank Corporation and SunTrust Banks, Inc.
Data is the sunlight that makes possible the fight against discrimination. The Consumer Financial Protection Bureau (CFPB), however, is considering changing its method of disseminating loan data that would make it less readily available to the public and significantly hamper our collective ability to root out unfair and discriminatory practices.
By 2021, the most popular and widely-used interest-rate benchmark, the London Interbank Offered Rate (LIBOR), will no longer exist as a benchmark for the $2 trillion in outstanding loans in the United States. In its place will most likely be the Secured Overnight Financing Rate (SOFR), which is broadly considered to be more robust and realistic than LIBOR. Nearly every borrower in the country that is paying off debt that is set based on the LIBOR will be affected by this change.
Data on community development lending and investing is lacking on a census tract level, making the information incomplete and difficult to assess. However, this is not the case for home mortgage lending data and small business loan data. If the federal regulatory agencies truly want to reform CRA, the first place to start is with better data. It would be a win-win for both banks and community organizations by facilitating identification of underserved areas. It would also further CRA’s objectives of directing access to credit and capital where it is needed most.