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 see:

• 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