HMDA/CRA: Common Errors & Performance Analysis Webinar
View this webinar featuring Joan Bateman, a FDIC Field Supervisor, and CRA guru, Len Suzio. This online seminar will focus on common HMDA and CRA data reporting errors that the FDIC finds during compliance examinations and will discuss some best practices for avoiding these errors.This will be followed by a presentation on how to analyze your CRA performance and how to turn your CRA "Cost Center" into a CRA "Profit Center".
Find out more and register Posted on: 1/17/2007
Rhode Island Emergency Regulations
"In the wake of negative responses to Rhode Island's emergency regulations implementing the RHODE Island Home Loan Protection Act, effective December 29, 2006, the Department of Business Regulation has tentatively scheduled a hearing for February 15, 2007 to respond to industry concerns. One of the biggest concerns is that lenders would be required to use the MAXIMUM rate on ARM loans to determine if the trigger test is met – which, effectively, would make a significant number of ARM loans in Rhode Island subject to the high cost provisions. The Department is currently informally soliciting and considering comments on the emergency regulations, which remain effective for 120 days following December 29, 2006."
Industry remains concerned with and somewhat confused by the disclosure requirements and the definitions, especially the definition of “fully indexed rate.” If the definition is meant to be interpreted as the highest rate that the loan may realize throughout the life of the loan, then the regulations could subject a higher number of loans to the high cost provisions of the statute. This, of course, could have a substantial impact on volume. However, more importantly, on the availability of credit to consumers wishing to own homes located in Rhode Island.
Posted on: 1/18/2007
How Do Examiners Measure CRA Performance?
By Len Suzio, President, GeoDataVision
The first thing to understand about CRA is that it boils down to a very simple question: “How does my bank meet our community's need for credit services?” Whenever you measure your bank's CRA performance you should always keep this in mind. This question has 3 built-in assumptions: (1) you know what your community's credit needs are, (2) you have loan products to meet those needs and (3) you have ways to measure how you are meeting those needs. Let's briefly review the first of these topics...
Read More Posted on: 1/18/2007
AFSA vs. Toledo Litigation Victory
The Ohio Supreme Court recently struck down the City of Toledo’s predatory lending ordinance. The Court applied its recent decision in AFSA vs. Cleveland without any further elaboration. See AFSA vs. Toledo, Nos. 2005-1240, 2005-1241 (Ohio Dec. 20, 2006) The Ohio Supreme Court held “that any local ordinances that seek to prohibit conduct that the state has authorized [in a general law] are in conflict with the state statutes and are therefore unconstitutional.”
This decision is consistent with other recent decisions stemming from lawsuits filed on the same issue. Courts have consistently ruled that regulatory authority for mortgage ending activity lies at the state level in the very least. In fact, the Ohio Supreme Court also recently reached this conclusion, November 2006, in AFSA vs. Cleveland, as did the California Supreme Court on January 31 2005 in AFSA v. Oakland.
Although the recent decision strikes down the ordinance, industry awaits similar word as to whether or not this decision applies to the ordinances in Summit County and Cleveland Heights – both in Ohio. As of press time, no word from the secondary market and no revisions to investor requirements.
Posted on: 1/18/2007