#redlining – Federal Financial Analytics

23 10, 2023

M102323

Eliza Allen2023-10-23T12:03:15-04:00October 23rd, 2023|6- Client Memo|

Why the New CRA Rules Won’t Serve Communities Any Better Than the Old CRA Rules

On Tuesday, the banking agencies will release the final version of their 679-page proposal to rewrite the Community Reinvestment Act. Regrettably, much of the proposal reflected the worst of false-science staff seeking complex new models defining subjective goals combined with certainty-loving compliance officers and lawyers who just want to be told the number they need to hit, not if the number makes any sense. Unsurprisingly, there were hundreds of comment letters in which banks generally said the agencies should ease up and community groups urged still more stringent standards. But the story doesn’t end with this unremarkable line-up– in just the last few months, two major bank trade associations and one often-virulently anti-bank advocacy group agreed on one crucial thing: anything close to what the agencies proposed won’t work.

m102323.pdf…

23 10, 2023

Karen Petrou: Why the New CRA Rules Won’t Serve Communities Any Better Than the Old CRA Rules

Eliza Allen2023-10-23T12:03:22-04:00October 23rd, 2023|The Vault|

On Tuesday, the banking agencies will release the final version of their 679-page proposal to rewrite the Community Reinvestment Act. Regrettably, much of the proposal reflected the worst of false-science staff seeking complex new models defining subjective goals combined with certainty-loving compliance officers and lawyers who just want to be told the number they need to hit, not if the number makes any sense. Unsurprisingly, there were hundreds of comment letters in which banks generally said the agencies should ease up and community groups urged still more stringent standards. But the story doesn’t end with this unremarkable line-up– in just the last few months, two major bank trade associations and one often-virulently anti-bank advocacy group agreed on one crucial thing: anything close to what the agencies proposed won’t work.

There are of course sharp differences between what banks and public advocates want in a new CRA rule, but what unites them is the over-arching understanding that the new approach is a cumbersome exercise remote from the reality confronting both banks and borrowers in the least-served urban and rural communities. Banks complain – often with good reason as I showed in my book on economic inequality – that risk-based capital rules over-estimate the risk of lending to many community-focused borrowers. The new capital proposals would ameliorate some of this in their “enhanced” risk weightings, but these weightings actually don’t count for much of anything since the proposed “higher-of” standards applies current, higher weightings.

The agencies in fact acknowledge as much …

25 04, 2023

DAILY042523

Eliza Allen2023-04-25T17:12:43-04:00April 25th, 2023|2- Daily Briefing|

Stablecoin 2.0 Is Controversial 3.0

Ahead of Thursday’s stablecoin hearing, HFSC Republicans late yesterday released a second discussion draft of legislation that received a most equivocal response at last week’s subcommittee hearing (see Client Report CRYPTO42).

Treasury Finds Profitability to Blame for De-Risking

Treasury today released its 2023 De-Risking Report, finding that profitability principally explains why financial institutions choose to de-risk.

OFR: No Single Factor To Blame For 2019 Repo Spike

A new OFR paper on the September 2019 repo rate spike concludes that while a confluence of factors – large Treasury issuances, corporate tax deadlines, and lower levels of reserves – caused the crisis, none of them individually would have been disruptive enough to trigger the spike, although limited transparency and market segmentation exacerbated it.

Federal Agencies Launch New Anti-AI Enforcement Effort

The FTC, the Civil Rights Division of the DoJ, CFPB, and EEOC today released a joint statement pledging to enforce all relevant consumer protection, anti-discrimination, and fair competition laws not only on AI, but indeed also on all “automated systems” that the agencies believe to be within their jurisdictions.

HFSC Digital Assets Hearing Set For Jurisdictional Debate

Ahead of Thursday’s hearing on the latest stablecoin discussing draft, HFSC’s staff memo today reiterates GOP opposition to the SEC’s jurisdictional arguments.

ONRRP Revised

The Federal Reserve Bank of New York today revised the terms of access to the overnight reverse-repo program, adding financial stability and bank safety-and-soundness to monetary-policy implementation as ONRRP criteria for eligible counterparties …

19 04, 2023

DAILY041923

Eliza Allen2023-04-19T17:26:14-04:00April 19th, 2023|2- Daily Briefing|

Hsu Treads Carefully Into Open Banking

In remarks today, Acting Comptroller Hsu highlighted the liquidity, cybersecurity, and even structural challenges that may arise from open banking. He argues that account portability may lead to heightened retail deposit liquidity risk and increased retail outflows, noting that online and mobile banking may well have facilitated the large outflows experienced by SVB and SBNY. Banks could require new cyber-risk controls due to the increase in volume and complexity of consumer data.

Chopra Expands Anti-Discrimination Campaign

Under heavy fire today from a staff data breach, CFPB Director Chopra nonetheless emphasized the agency’s strong stand against credit discrimination. Building on a recent statement of interest in a filing related to student loan litigation, the Bureau is now not only combatting traditional forms of discrimination, but also the targeting Mr. Chopra describes as reverse redlining across the spectrum of consumer-finance products and every contact point in the credit origination, servicing, marketing, and technology process.

Daily041923.pdf…