Understanding the CFPB’s Expectations through Enforcement

Once a quarter, the Consumer Finance Protection Bureau publishes a report of actions it’s taken to enforce compliance matters across the spectrum of consumer finance products. This report, called Supervisory Highlights, often contains valuable insights into how the Bureau is collecting, interpreting and acting on the data it collects. And according to Director Richard Cordray, […]

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 discrimination under […]

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 REMA. Reasonably […]