Let’s recap what has happened in 2024 on three different fronts: HMDA, fair lending, and CRA (the Community Reinvestment Act). I count six important developments. These are listed in no particular order below: 1. OMB released a new MSA list in 2023, which was incorporated by the FFIEC in 2024. Some new MSAs and Metropolitan Divisions were created. The tract income categories for many census tracts were revised. And also, Connecticut relabeled all of their census tracts to include the “planning regions” rather than county.
2. The 2023 HMDA Snapshot data were released in July 2024. A couple of observations:
a) Generally high-interest rates led to a continued drop in refinancings in 2023. The number and volume of refinancing loans decreased by 87.7% and 87.3%, respectively, between 2020 and 2023. There was also a smaller decline (35.6%) in the number of home purchase loans between 2021 and 2023.
b) Institutions that originated between 25 and 99 (inclusive) closed-end loans were technically required to report HMDA data for the 2022 calendar year, but as a practical matter, there were no penalties for failure to report. On the other hand, for 2023, such institutions were required to report. According to an analysis in LendingPatterns™ of the 2023 Snapshot, there were 687 lenders who originated between 25 and 99 closed-end loans.
3. DOJ enforcement actions: The Combatting Redlining Initiative, announced by the DOJ, CFPB, and OCC in 2021, led to the noteworthy resolution of five redlining enforcement cases in 2024. In total, DOJ consent orders have led to more than $150 million in penalties. All six of the institutions alleged to have redlined in 2023 were banks. However, in 2024, there were three banks, one credit union, and one non-depository mortgage company.
4. In 2023, the CFPB issued a Final Rule implementing Dodd-Frank Section 1071, which covers small business lending data collection. As a result of related court orders, the CFPB pushed back the dates on which institutions are required to begin collecting loan information. The highest volume lenders are scheduled to begin collecting in July 2025, and lower-volume lenders will begin later.
5. The final text of an OCC/FDIC/Federal Reserve rule affecting the regulations that implement the Community Reinvestment Act (CRA) was published in the Federal Register on February 1, 2024. 6. HMDA Filing Instruction Guide (FIG) updates: The most recent revision to the 2025 FIG came in September 2024. This guide was previously downloadable in PDF format and is now entirely online.
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