State Community Reinvestment Act Requirements for Independent Mortgage Banks
MBA Opposes State Efforts to Impose Community Reinvestment Act Standards on Independent Mortgage Banks.
Overview: Regulators and legislators are considering options to extend the reach of the Community Reinvestment Act (CRA) to independent mortgage banks (IMBs). These policy options represent a solution in search of a problem and do not recognize the incompatibility of the CRA with the business models of IMBs and their historical lending activities.
Independent Mortgage Banks:
- do not have deposits to reinvest;
- do not have access to direct government support;
- already engage in sustainable lending in low- to moderate-income (LMI) communities; and,
- are subject to robust oversight and supervision in every state they operate as well as from federal regulators.
The application of the Community Reinvestment Act to independent mortgage banks would be an ineffective and misguided policy choice.
Recent MBA Activity Related to State CRA Proposals for IMBs
- IMBs and the CRA: A Misguided Match, by MBA President and CEO Bob Broeksmit, CMB
- MBA Policy Paper: Applying CRA to Independent Mortgage Banks:An Ineffective and Misguided Policy Choice
- MBA Policy Paper: Independent Mortgage Banks: Financing the American Dream
Selected State HMDA Data Sheets of IMB Lending to LMI Borrowers
Data Sheet Available for Download
- Click State to Download Datasheet
Related State CRA News
- December 16, 2021: MBA and Illinois MBA Submit Comments to Illinois DFPR Regarding Advanced Notice of Proposed Rulemaking on Illinois CRA law.
- November 1, 2021: New York Governor Announces Her Approval of CRA Bill for Independent Mortgage Banks
- August 26, 2021: MBA and Illinois MBA Submit Testimony to Illinois DFPR Regading Implentation of CRA Apropos to Independent Mortgage Banks
- August 9, 2021: Housing Wire - MBA Urges Cuomo to Veto New York IMB bill
- July 26, 2021: Illinois Department of Financial and Professional Regulation announces Advanced Notice of Proposed Rulemaking (ANPR)
- July 26, 2021: American Banker (subscription required), Will States Lead the Way on Expanding CRA to Nonbanks?
- July 23, 2021: MBA Letter Requesting Veto of New York CRA Legislation
- July 1, 2021: One Small Step for New York, One Large Misstep for Housing Finance, American Action Forum