State Community Reinvestment Act (CRA) Legislation
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. Applying the Community Reinvestment Act to IMBs would be an ineffective and misguided policy choice that MBA opposes.
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
- Are subject to robust oversight and supervision in every state they operate as well as from federal regulators
For more information about IMBs, please download:
- MBA Works for IMBs: IMB Special Report
- Urban Institute: An Assessment of Lending to LMI and Minority Neighborhoods and Borrowers (April 2023)
- IMB Fact Sheet: Independent Mortgage Banks: Financing the American Dream
- IMB Policy Spotlight: Independent Mortgage Banks and Community Reinvestment Requirements: A Solution in Search of a Problem
- MBA White Paper: Applying CRA to Independent Mortgage Banks: An Ineffective and Misguided Policy Choice
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
- March 6, 2024: MBA submits comments to the Illinois Department of Financial and Professional Regulation regarding re-proposed state CRA regulations.
- February 27, 2024: Maryland legislation (HB-1135) receives costly fiscal note, and subsequently removed from consideration in House Economic Matters Committee meeting. Bill withdrawn by Sponsor 3/4/24.
- January 12, 2024: Illinois Department of Financial and Professional Regulation publishes new proposed CRA regulations. Note: for IMBs (pages 7-80 of the document), community banks (pages 81-144) and credit unions (pages 151-184).
- November 3, 2023: MBA and Illinois Mortgage Bankers Association submitted comments to the Illinois Department of Financial and Professional Regulation and the Joint Committee on Administrative Rules in response to the September Second Notice proposal.
- September 29, 2023: Illinois regulator released revised proposed CRA regulations for IMBs, community banks, and credit unions.
- April 17, 2023: Nonpartisan Urban Institute Report - An Assessment of Lending to LMI and Minority Neighborhoods and Borrowers: Performance of Independent Mortgage Banks in the Context of CRA Reform
- March 16, 2023: MBA and Illinois MBA submit comments on proposed regulations for CRA implementation.
- March 14, 2023: Legislation (SB-498) introduced in Pennsylvania to implement CRA for non-banks and banks.
- March 2, 2023: Illinois MBA delivers testimony on CRA during Department of Financial and Professional Regulation hearing.
- January 26, 2023: Maryland House of Delegates introduces legislation (HB0392) to apply CRA mandates to IMBs, credit unions, and state-charted banks. February 28, 2023 UPDATE: Bill withdrawn by sponsor.
- January 26, 2023: Illinois DFPR extends comment period for new CRA rules and announces public hearings.
- December 2022: Illinois DFPR publishes proposed rules to implement the Illinois Community Reinvestment Act. MBA and Illinois MBA submit a letter to Illinois DFPR, urging to extend the comment period.
- September 2022: The AARMR Regulator Perspective: Independent Mortgage Banks and Community Reinvestment Requirements: A Solution in Search of a Problem (page 16)
- May 19, 2022: California Senate Judiciary Committee significantly amends SB 1176; Senate approves bill. NOTE: Legislation was not passed prior to end of 2022 legislative session.
- March 2022: California MBA Opposition Letter on Senate Bill 1176
- February 21, 2022: Urban Institute Report: Who Serves More People of Color in Mortgage Lending: Banks or Nonbanks?
- February 17, 2022: California Senate introduces bill to apply CRA to nonbanks.
- 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 regarding implementation of CRA apropos to independent mortgage banks.
- August 9, 2021: Housing Wire: MBA and NY MBA Urge Governor 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 penned 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
Key State CRA Statutes and Regulations for IMBs
- Massachusetts Nonbank CRA Law, Regulations, and CRA Webpage
- Illinois Nonbank CRA Law (see Article 35)
- New York Nonbank CRA Law
