Redlining: A Compliance Officer’s Primer

In today’s regulatory environment, most compliance officers are keenly aware of the fact that redlining is one of three 2017 foci for the CFPB and probably for the prudential regulators as well.  The purpose of this article is to highlight the key elements in any redlining analysis and thereby make it easier for compliance officers […]

Peer! Peer! Who Is Your Peer?

The Fall 2016 edition of the Consumer Finance Protection Bureau’s Supervisory Highlights devoted several pages to the topic of redlining. Some of what the CFPB had to say about fair lending was not new—for example, that “redlining is a priority area in the Bureau’s supervisory work” or that “redlining is a form of unlawful lending […]

REMA: Reasonably Expected Market Area

Recently I attended a seminar where a Federal Deposit Insurance Corporation representative used the term “REMA” in a discussion of redlining risk. Have you heard the term? It’s a helpful acronym to know if you desire to understand how the FDIC makes determinations about redlining. What follows borrows heavily from the FDIC representative’s comments on […]