Fair Lending and Related Mortgage Development Updates: Community Reinvestment
Review developments, including requirements imposed on nondepository mortgage lenders.
The federal Community Reinvestment Act (CRA) began as an attempt to ensure that depository institutions (excluding credit unions) reinvested through lending in their “footprint” market areas amounts comparable to the deposits received from their customer base in those market areas. Depository institutions are rated on how well they perform under the CRA. Poor CRA ratings make it difficult for a depository institution to receive regulatory approvals for new branch openings, mergers, acquisitions, and other matters. This white paper reviews community reinvestment requirements and the importance of complying with the recordkeeping requirements of Regulation B with respect to loan applications, adverse action notices, loan approvals, and other documents listed in the regulation, as well as HMDA.
Partner in the New Haven, Connecticut, office of Hudson Cook LLP, headquartered in Maryland
Past chair of the Truth in Lending Subcommittee of the Consumer Financial Services Committee of the American Bar Association's Section of Business Law
Past chair of the Consumer Law Section of the Connecticut Bar Association
Fellow of the American College of Consumer Financial Services Lawyers, and a member of the Conference on Consumer Finance Law and the Board of Editors of The Banking Law Journal (a LexisNexis A.S. Pratt publication)
J.D. degree, cum laude, University of Michigan Law School