#HMDA – Page 2 – Federal Financial Analytics

8 09, 2021

SBA40

Arezou Rafikian2023-08-21T13:45:46-04:00September 8th, 2021|1- Financial Services Management|

Small-Business Lending Disclosures

Turning again to a provision in the 2010 Dodd-Frank Act, the Bureau of Consumer Financial Protection has issued a sweeping proposal to implement small-business and small-farm lending disclosure requirements akin to those long required under the Home Mortgage Disclosure Act (HMDA). Although the law focuses on lender reports to discern different loan-approval rates based on gender or ethnic/racial groups, the notice of proposed rulemaking (NPR) goes farther also to require extensive detail on loan amounts and pricing on approved loans a borrower chooses not to accept. Data would be required from all but the very smallest bank and nonbank lenders.

SBA40.pdf…

8 09, 2021

SMBUS27

Arezou Rafikian2023-08-21T13:53:42-04:00September 8th, 2021|1- Financial Services Management|

Small-Business Lending Disclosures
Turning again to a provision in the 2010 Dodd-Frank Act, the Bureau of Consumer Financial Protection has issued a sweeping proposal to implement small-business and small-farm lending disclosure requirements akin to those long required under the Home Mortgage Disclosure Act (HMDA). Although the law focuses on lender reports to discern different loan-approval rates based on gender or ethnic/racial groups, the notice of proposed rulemaking (NPR) goes farther also to require extensive detail on loan amounts and pricing on approved loans a borrower chooses not to accept. Data would be required from all but the very smallest bank and nonbank lenders.

SMBUS27.pdf…

7 09, 2021

Karen Petrou: The Coming Fair-Lending Fracas

Arezou Rafikian2023-08-22T12:43:29-04:00September 7th, 2021|The Vault|

A week ago Thursday, I was honored to participate in a Congressional Black Caucus Foundation forum assessing the extent to which the Fed exacerbates U.S. economic inequality. Views were mixed on that front, but several panelists stoutly condemned financial institutions for actively discriminating against people and communities of color and the Fed for allowing them to get away with it. That won’t be the last we hear of this.

As our recent assessment of the latest mortgage data make clear, these allegations are not without merit. That underlying factors are complex and sometimes include contradictory evidence does not belie the fact that data remain problematic, the industry is deeply distrusted, and the White House has made racial equity a top-priority Presidential action item. First to what the data do and don’t show and then to what will be done about them unless some of the things that can instead be done are quickly done.

The latest HMDA data show troubling denial disparity ratios (DDRs), interest-rate, and cost disparities when minorities are compared to whites. The DDR for Blacks was 2.6:1, rates were .125 percentage points higher, and the cost of a loan was 38% more. Black credit scores were the lowest among demographic groups (690) and loan amounts were the smallest, but these differences are still striking.

Little noticed but even more puzzling are the DDRs for Asians versus whites. Asian DDRs were 1.4:1 even though credit score and loan amounts were the highest of all demographic groups. …

2 09, 2021

Daily090221

Arezou Rafikian2023-08-22T12:51:44-04:00September 2nd, 2021|2- Daily Briefing|

BIS Advances CBDC Cross-Border Settlement
Continuing CBDC work sure to put still more pressure on the Fed to advance its own efforts, the BIS today announced a flagship pilot with three major central banks testing a DLT-based approach to cross-border settlement.

Uejio Defends Demographic, Price Data Demand
Following release of its small business data collection proposal, CFPB Acting Director Uejio late yesterday confirmed our assessment that the CFPB wants HMDA-like demographic and price data for small business lending.

DOJ Takes New, Tough Tack on Small Regional M&A
Although the asset and branch divestitures in the BancorpSouth/Cadence merger are relatively standard, the Department of Justice announcement today emphasized the pro-competition position germane even to rural and small-bank mergers laid out in President Biden’s recent executive order (see Client Report MERGER6).

Daily090221.pdf…

1 09, 2021

Daily090121

Arezou Rafikian2023-08-22T12:59:13-04:00September 1st, 2021|2- Daily Briefing|

Affordable Rentals, Manufactured Housing Get Boost from White House, FHFA
The Biden Administration today announced a raft of housing policy changes to boost affordable housing.

Gensler Tells EU: SEC to Press Crypto, Climate, Digital-Brokerage Regs
In comments to EU legislators today, SEC Chairman Gensler not only stood by his ambitious agenda, but also placed it in the broad context of global developments.

CFPB Announces Sweeping Plan to Gather HMDA-Style Data for Small-Business Lending
Following through on Acting Director Uejio’s pledge to quickly implement Dodd-Frank mandated small-business lending data collections after these were slow walked under former Director Kraninger, the CFPB today proposed to require lenders to disclose detailed information in this sector going well beyond the simple requirements in traditional ECOA reports.

Daily090121.pdf…