- Source: consumerfinance.gov
The CFPB continues to expand its influence with regards to all financial products offered by all types of financial organizations. The CFPB does not have statutory authority over the Community Reinvestment Act (CRA), but it is apparent they participated in the recent CRA modernization efforts and have opinions the availability of financial products to low-and moderate- income individuals. The CFPB, in its report, states it will continue to monitor state CRA developments.
It is important for all organizations that provide financial products to understand the requirements of state as well as federal laws. Treliant assists organizations in assessing current CRA programs, determining applicability of state laws, and implementing the newest CRA modernization rule during this time of heightened focus.
On November 2, 2023, the CFPB released an analysis of state CRA laws. The report focused on the laws from the seven states (Connecticut, Illinois, Massachusetts, New York, Rhode Island, Washington, West Virginia) and the District of Columbia.
New York state was the first to adopt its own CRA into law in 1978 with Massachusetts the second state to pass such a law. The most recent to pass a law was Illinois on January 13, 2021. While, the current Community Reinvestment Act and most recent finalized changes only apply to banks, coverage of the various state laws vary applying to banks, mortgage companies, credit unions and other regulated entities. The analysis reviewed institutional coverage, examination structure, metrics reviewed, data sources and enforcement mechanisms of the states included in the report.
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