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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:

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

  • February 5, 2025: CRA legislation (HB-1040) introduced in Maryland, but withdrawn by sponsor within a week (2/10/25)
  • February 5, 2025: NY Department of Financial Services officially published its proposed CRA regulations in the New York State Register.
  • January 22, 2025: CRA legislation (SB-119) re-introduced in Pennsylvania.
  • December 31, 2024: MBA, NYMBA and local groups submit comments to NY Department of Financial Services on CRA proposal.
  • December 18, 2024: MBA urges Illinois Department of Financial and Professional Regulation to provide clarity on new IMB CRA examination fee structure.
  • December 17, 2024: NY Department of Financial Services issues press release that included a link to the text of a draft regulation to implement IMB CRA law, and provides a “pre-proposal” comment opportunity.
  • September 16, 2024: MBA submits comments to the Illinois Department of Financial and Professional Regulation raising questions on proposed fee structure changes to the Illinois CRA
  • August 2, 2024: Illinois proposes fee structure changes for independent mortgage bankers subject to the Illinois Community Reinvestment Act 
  • 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

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