The stated intentions of Green Dot Bank to meet its obligations under the Community Reinvestment Act demonstrate the inability of the 1977 law to adapt to changes in today’s banking system.

As a condition for the Federal Reserve‘s approval of Green Dot’s application to buy Bonneville (more…)

The Dodd-Frank bill will require lenders to disclose more data about their lending, but the fundamental problems with HMDA remain largely unresolved. Dodd-Frank says that it will collect, and then disseminate, the following new categories within an updated HMDA by no later than 2012:

• age of borrower
• borrower credit score
• total points and fees payable at origination
• the spread between the loan’s interest rate and the corresponding treasury note of similar maturity
• value of the collateral pledged against the loan
• non-amortizing loan features
• length before loan reset (months)

Those are some good ideas. I think that there is going to be a substantial discussion about (more…)

One of the problems with the enforcement of the Community Reinvestment Act has been the inability of examiners to create standards that can distinguish the level of effort made by different banks and thrifts. The problem isn’t just with the ratings, although they are certainly guilty of this sin. It lies in the construction of examinations, as well.

Community development loans are one of the most significant ways that a bank can extend credit that would otherwise not be available. Loans for (more…)

Minutes ago, the Office of the Comptroller of the Currency demonstrated once again why no one takes their CRA exams very seriously.

The OCC released evaluations for 27 banks.  All of the evaluations were made from October 15th through November 14th.  No banks were given any grades that would reflect shortcomings in service, lending, or investment to their local areas.  Twenty-five passed, and two passed with “outstanding” colors.

How good is an “outstanding?”  Well, the people who run your credit card are apparently doing an outstanding job at making you happy.  Citibank (South Dakota) NA received an outstanding.  Did they do an outstanding job? Sure, maybe they are charging millions of Americans up to 29.9 percent on their credit card debt, but they did it well, right?

Drilling down to Citibank’s evaluation, it is easy to see some of the reasons for why the CRA needs to be (more…)

Today’s Miller-Moore amendment makes more sense than would first appear.  The new rule, coming out of the House Financial Services Committee, exempts most financial institutions from new regulatory review by the proposed CFPA.

Banks with assets under $10 billion, and credit unions with assets under $1.5 billion, would not be examined by the CFPA.  It seems like a cave-in, right?  What’s up with the lobbyists giving up on so much work from those 8,000 clients? What’s up with helping the country prevent another meltdown?

Advocates initially responded with some frustration.  The National Community Reinvestment Coalition published a (more…)