Community Reinvestment Act

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The Community Reinvestment Act (or CRA, Pub. L.Tooltip Public Law (United States) 95–128, title VIII, 91 Stat. 1147, 12 U.S.C. § 2901 et seq.) is a United States federal law designed to encourage commercial banks and savings associations to help meet the needs of borrowers in all segments of their communities, including low- and moderate-income neighborhoods, consistent with safe and sound operations.[1][2] The Act requires appropriate federal financial supervisory agencies to encourage regulated financial institutions to meet the credit needs of the local communities in which they are chartered consistent with the safe and sound operation. (See full text of Act and current regulations.[3]) The Act was intended to expand access to credit and reduce discriminatory credit practices – such as targeting only wealthier neighborhoods with their services, a practice known as "redlining."[4] The Act was passed in 1977 and has been subjected to important regulatory revisions since then.

Original Act

The CRA was passed by the 95th United States Congress and signed into law by President Jimmy Carter in 1977 as a result of national pressure for affordable housing.[5] Before the Act was passed, there were severe shortages of credit available to low- and moderate-income neighborhoods, as well as concerns about redlining and discrimination.[4] In Congressional debate on the Act, critics charged that the law would "distort credit markets, create unnecessary regulatory burden, lead to unsound lending, and cause the governmental agencies charged with implementing the law to allocate credit." In response Congress included little prescriptive detail and gave agencies considerable regulatory flexibility.[6]

The CRA mandates that each banking institution be evaluated to determine if it has met the credit needs of its entire community, in a manner consistent with safe and sound operations. That record is taken into account when the federal government considers an institution's application for deposit facilities. The Act charged the Federal Reserve System to implement the CRA through ensuring banks and savings and loans met their CRA obligations.[5] The CRA is also enforced by the Federal Deposit Insurance Corporation ("FDIC") CRA Statute. Community groups only slowly organized to take advantage of their right under the Act to complain about law enforcement of the regulations.[7][8]

Legislative Changes 1989 - 1994

The Financial Institutions Reform Recovery and Enforcement Act of 1989 (FIRREA) was enacted by the 101st Congress and signed into law by President G. H. W. Bush in the wake of the savings and loan crisis of the 1980s. As part of a general reform of the banking industry, it increased public oversight of the process of issuing CRA ratings to banks. It required the agencies to issue CRA ratings publicly and written performance evaluations using facts and data to support the agencies' conclusions. It also required a four-tiered CRA examination rating system with performance levels of "Outstanding," "Satisfactory," "Needs to Improve," or "Substantial Noncompliance."[6]

According to Ben Bernanke, Chair of the Federal Reserve System since 2006, this law greatly increased the ability of advocacy groups, researchers, and other analysts to "perform more-sophisticated, quantitative analyses of banks' records," thereby influencing the lending policies of banks. Over time, community groups and nonprofit organizations established "more-formalized and more-productive partnerships with banks."[5]

Bernanke also stated that CRA was affected by the United States Congress passing the Federal Housing Enterprises Financial Safety and Soundness Act of 1992. This act required the Federal National Mortgage Association, commonly known as Fannie Mae, and the Federal Home Loan Mortgage Corporation, commonly known as Freddie Mac, to devote a percentage of their lending to support affordable housing. This in part, contributed to increased Fannie Mae and Freddie Mac pooling and selling of such loans as securities, (i.e. securitization), and expanded the secondary market for those loans.[5]

In 1997, First Union Capital Markets and Bear, Stearns & Co launched the first public securitization of CRA loans, issuing $384.6 million of such securities.[9] Between 2000 and 2002 Fannie Mae securitized $394 billion in CRA loans with $20 billion going to securitized mortgages."[10] In 2000, in order to expand the secondary market for affordable community-based mortgages and to increase liquidity for CRA-eligible loans, Fannie Mae committed to purchase and securitize $2 billion of "MyCommunityMortgage" loans. [11][12]

The Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 which repealed restrictions on interstate banking specifically noted the necessity for looking at ratings received under the Community Reinvestment Act.[13] Bernanke explains that because of the subsequent surge in bank mergers and acquisitions activities, advocacy groups increasingly protested such bank applications on CRA grounds. Agencies began to hold public hearings to allow such comment. In response many institutions established separate business units and corporations to facilitate CRA-related lending. To expand and manage such CRA-related local and regional public-private partnerships and multibank loan consortia were formed and gained more prominence.[5]

Administrative Changes 1995

In July 1993 President Clinton asked regulators to reform the CRA in order to reduce paperwork and reward performance. As the Administration said in a press briefing, "The only thing that ought to matter on a loan application is whether or not you can pay it back, not where you live." [14] The CRA regulations were substantially revised and adopted objective quantitative measures in place of the prior subjective qualitative measures - using federal home-loan data broken down by neighborhood, income group, and race; encouraging community groups to complain when banks were not loaning enough to specified neighborhood, income group, and race; allowing community groups that marketed loans to targeted groups to collect a fee from the banks just like other loan product marketers.[6]

During March 1995 congressional hearings William A. Niskanen, chair of the Cato Institute, criticized the proposals for political favoritism in allocating credit and micromanagement by regulators, and that there was no assurance that banks would not be expected to operate at a loss. He predicted they would be very costly to the economy and banking system, and that the primary long term effect would be to contract the banking system. He recommended Congress repeal the Act.[15]

Responding to concerns that the CRA would lower bank profitability, a 1997 research paper by economists at the Federal Reserve found that "[CRA] lenders active in lower-income neighborhoods and with lower-income borrowers appear to be as profitable as other mortgage-oriented commercial banks".[16] Speaking in 2007, Federal Reserve Chair Ben Bernanke noted that, "managers of financial institutions found that these loan portfolios, if properly underwritten and managed, could be profitable" and that the loans "usually did not involve disproportionately higher levels of default".[5]

Howard Husock, vice-president of the market-oriented conservative Manhattan Institute and author of a book on American housing policy, writes that once in effect, the new rules substantially increased the number and aggregate amount of loans to low- and moderate-income borrowers for home loans. The Senate Banking Committee estimated that as of 2000, as a result of CRA, such groups had received $9.5 billion in services and salaries. As of that time such groups also had received tens of billions of dollars in multi-year commitments from banks to loan to local communities, including the ACORN housing advocacy organization $760 million; Boston-based Neighborhood Assistance Corporation of America $3 billion; a New Jersey Citizen Action-led coalition $13 billion; the Massachusetts Affordable Housing Alliance $220 million.[17]

According to a United States Department of the Treasury study of lending trends in 305 U.S. cities between 1993 and 1998, 467 billion dollars in mortgage credit flowed from CRA-covered lenders to CRA-eligible borrowers. The number of CRA mortgage loans increased by 39 percent. Other loans increased by only 17 percent.[18]

Legislative Changes 1999

In 1999 the Congress enacted and President Clinton signed into law the Gramm-Leach-Bliley Act, also known as the "Financial Services Modernization Act," which repealed the part of the Glass-Steagall Act prohibiting a bank from offering a full range of investment, commercial banking, and insurance services. The bill was killed in 1998 because Senator Phil Gramm wanted the bill to expand the number of banks which no longer would be covered by the CRA. He also demanded full disclosure of any financial deals which community groups had with banks, accusing such groups of "extortion." In 1999 Senators Christopher Dodd and Charles E. Schumer broke another deadlock by forcing a compromise between Gramm and the Clinton administration which wanted to prevent banks from expanding into insurance or securities unless they were compliant with the CRA. In the final compromise, the CRA would cover bank expansions into new lines of business, community groups would have to disclose certain kinds of financial deals with banks, and smaller banks would be reviewed less frequently for CRA compliance.[19][20][21] On signing the Gramm-Leach-Bliley Act, President Clinton said that it, "establishes the principles that, as we expand the powers of banks, we will expand the reach of the [Community Reinvestment] Act".[22]

Administrative Changes 2005

In 2002 there was an inter-agency review of the effectiveness of the 1995 regulatory changes to the Community Reinvestment Act and new proposals were considered.[6] In early 2005, the Office of Thrift Supervision (OTS) implemented new rules that – among other changes – allowed thrifts with over $1 billion in assets to meet their CRA obligations without regard to services for, or investments in, their communities.[23] In April 2005, a contingent of Democratic Congressmen issued a letter protesting these changes, saying they undercut the ability of the CRA to "meet the needs of low and moderate-income persons and communities".[23]

The Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System, and the Office of the Controller of the Currency put a new set of regulations into effect in September 2005.[24] The regulations included less restrictive new definitions of "small" and "intermediate small" banks.[5] "Intermediate small banks" were defined as banks with assets of less than $1 billion, which allows these banks to opt for examination as either a small bank or a large bank.[24] Currently banks with assets greater than $1.061 billion have their CRA performance evaluated according to lending, investment and service tests. The agencies use the Consumer Price Index to adjust the asset size thresholds for small and large institutions annually.[6]

Proposals to expand impact 2007 - 2008

In 2007 Ben Bernanke suggested further increasing the presence of Sallie Mae and Freddie Mac in the affordable housing market to help banks fulfill their CRA obligations by providing them with more opportunities to securitize CRA-related loans.[25]

In April of 2008 an FDIC official stated the FDIC was exploring offering incentives for banks to offer low-cost alternatives to payday loans. Doing so would allow them favorable consideration under their Community Reinvestment Act responsibilities. It had recently begun a two-year pilot project with an initial group of 31 banks.[26]

Controversies

The effects of the Community Reinvestment Act on the housing markets are controversial for a variety of issues.

Effectiveness

Some economists and financial experts have wondered if the CRA was - or at least had become - irrelevant, because it was not needed to force banks to make profitable loans to a variety of lenders.[27][28] In a 2003 research paper, economists at the Federal Reserve could not find clear evidence that the CRA increased lending and home ownership more in low income neighborhoods than in higher income ones.[8] A 2008 Competitive Enterprise Institute study resulted in a similar finding.[29]

The Woodstock Institute, a Chicago-based policy and advocacy nonprofit, found in an analysis of 1996 Chicago-area survey data that low income areas still lagged behind in access to commercial loans. Most small business loans made by CRA regulated banks went to higher income areas; 16.6% in low-income areas, 18.4% in low- and moderate-income tracts; 21.8% in middle-income areas and 23.1% in upper-income areas.[30]

Other studies found the CRA program highly effective. As noted above in the "Administrative Changes 1995" section, "according to a United States Department of the Treasury study of lending trends in 305 U.S. cities between 1993 and 1998, 467 billion dollars in mortgage credit flowed from CRA-covered lenders to CRA-eligible borrowers. The number of CRA mortgage loans increased by 39 percent. Other loans increased by only 17 percent." A 130% greater increase in the number of CRA mortgage loans relative to other loans.

Housing advocacy groups

In an article for the New York Post, economist Stan Liebowitz wrote that community activists intervention at yearly bank reviews resulted in their obtaining large amounts of money from banks, since poor reviews could lead to frustrated merger plans and even legal challenges by the Justice Department.[31] Michelle Minton noted that Chase Manhattan and J.P. Morgan donated hundred of thousands of dollars to ACORN at about the same time they had were to apply for permission to merge and needed to comply with CRA regulations.[29]

According to the New York Times, some of these housing advocacy groups provided early warnings about the potential impact of lowered credit standards and the resulting unsupportable increase in real estate values they were causing in low to moderate income communities. Ballooning mortgages on rental properties threatened to require large rent increases from low and moderate income tenants that could ill afford them. Cite error: The <ref> tag has too many names (see the help page).

Predatory Housing Lending

In 1980, Congress passed the Depository Institutions Deregulation and Monetary Control Act exempting federally chartered savings banks, installment plan sellers and chartered loan companies from state usury limits.[32] The 1968 Truth in Lending Act does not regulate rates, except in the cases of some mortgages, but it does require uniform or standardized disclosure of costs and charges.[33]

In 2002 Kathleen C. Engel and Patricia A. McCoy published a study of the predatory lending implications of the CRA, noting that by the late 1990s, predatory high cost mortgages to “gullible borrowers” were leading to foreclosures against low-income people of color and the elderly. They found evidence of such lending practices by CRA covered banks, both directly in their own lending and indirectly in buying other parties’ predatory loans as investments or to help them obtain CRA compliance credit. They criticized CRA regulators for not punishing such predatory lending and recommended changes to make it do so.[34] Other analysts and community groups also complained about this problem in the early 1990s.[35][36]

The FDIC has tried to address this issue by "stopping abusive practices through the examination process and supervisory actions; encouraging banks to serve all members and areas of their communities fairly; and providing information and financial education to help consumers make informed choices". FDIC policy currently states that "predatory lending can have a negative effect on a bank's CRA performance."[37]

Relation to 2008 financial crisis

See also: Subprime mortgage crisis

In an article for the New York Post, economist Stan Liebowitz wrote that the CRA encouraged a loosening of lending standards throughout the banking industry despite warnings of default. Banks were allowed to loan to consumers who were not credit worthy with "no verification of income or assets; little consideration of the applicant's ability to make payments; no down payment." According to Liebowitz, the chief executive of Countrywide Financial said that in order to approve minority applications, "lenders have had to stretch the rules a bit."[31]

In a piece for CNN, Congressman Ron Paul, who serves on the United States House Committee on Financial Services, partially attributed the current economic downturn to the Community Reinvestment Act, charging it with "forcing banks to lend to people who normally would be rejected as bad credit risks."[38]

A Wall Street Journal editorial on the 2008 financial crisis argued that "Washington is as deeply implicated in this meltdown as anyone on Wall Street" because politicians "promoted housing and easy credit". The editorial lists the CRA as as one of the "subsidies and policies," and stated that it "compels banks to make loans to poor borrowers who often cannot repay them".[39]

In an article for the Wall Street Journal, Austrian school economist Russell Roberts blamed the combined effects of excessive Federal Reserve credit expansion, the CRA, the implied guarantee to Fannie Mae and Freddie Mac, the Taxpayer Relief Act of 1997, and other policies for causing the crisis.[40]

Others dispute the CRA's involvement in the crisis.

In congressional testimony in 2008, University of Michigan law professor Michael S. Barr, a Treasury Department official under President Bill Clinton,[41][22] stated that a Federal Reserve survey showed that affected institutions considered CRA loans profitable and not overly risky. He noted that approximately 50% of the subprime loans were made by independent mortgage companies that were not regulated by the CRA. Another 25% to 30% came from only partially CRA regulated bank subsidiaries and affiliates. He stated that institutions fully regulated by CRA made "perhaps" one in four sub-prime loans. Referring to CRA and abuses in the subprime market, Michael Barr stated that in his judgment "the worst and most widespread abuses occurred in the institutions with the least federal oversight". [42]

Assistant Professor of Law Alan M. White[43] notes that some abuses blamed on CRA actually occurred because under the G. W. Bush administration Housing and Urban Development and Office of Federal Housing Enterprise Oversight regulators allowed Fannie Mae and Freddie Mac to fulfill their affordable housing goals, which are not technically part of the CRA, by buying subprime mortgage-backed securities.[44]

In a Bank for International Settlements ("BIS") working paper, economist Luci Ellis concluded that "there is no evidence that the Community Reinvestment Act was responsible for encouraging the subprime lending boom and subsequent housing bust."[45]

According to Janet L. Yellen, President of the Federal Reserve Bank of San Francisco, independent mortgage companies made "high-priced loans" at more than twice the rate of the banks and thrifts. She states that most CRA loans have been responsibly made, and are not the higher-priced loans that have contributed to the current crisis.[46]

In 2008, Traiger & Hinckley LLP, a law firm that counsels financial services entities on CRA compliance, conducted a study of loans made by institutions covered under the CRA. The study found that CRA regulated institutions were less likely to make subprime loans, and when they did the interest rates were lower. CRA banks were also half as likely to resell the loans to other parties.[47]

Ellen Seidman, former director of the US Office of Thrift Supervision during the Clinton administration, who works at the New America Foundation,[48] has stated that the CRA did not have an effect on the United States housing bubble.[49] She noted that CRA banks were particularly warned to make responsible investments, and cited one of her own speeches as an example.[50]

References

  1. ^ "Community Reinvestment Act". Federal Reserve. Retrieved 2008-10-05.
  2. ^ Avery, Robert B. (November, 2000). "The Performance and Profitability of CRA-Related Lending". Economic Commentary. Federal Reserve Bank of Cleveland. Retrieved 2008-10-05. {{cite web}}: Check date values in: |date= (help); Unknown parameter |coauthors= ignored (|author= suggested) (help)
  3. ^ Text of Housing and Community Development Act of 1977—title Viii (Community Reinvestment).
  4. ^ a b Thompson, Sandra L (2008-2-13). "Statement of Sandra L. Thompson, Director, Division of Supervision and Consumer Protection". FDIC. Retrieved 2008-10-05. {{cite web}}: Check date values in: |date= (help)
  5. ^ a b c d e f g Ben S. Bernanke, Chair of Federal Reserve System, The Community Reinvestment Act: Its Evolution and New Challenges, speech at the Community Affairs Research Conference, Washington, D.C., Federal Reserve System website, March 30, 2007.
  6. ^ a b c d e Sandra F. Braunstein, Director, Division of Consumer and Community Affairs, The Community Reinvestment Act, Testimony Before the Committee on Financial Services, U.S. House of Representatives, 13 February 2008.
  7. ^ Schwartz, A., From confrontation to collaboration? Banks, community groups, and the implementation of community reinvestment agreements, Fannie Mae, 3, pp. 631-662, 1998.
  8. ^ a b Robert B. Avery, Paul S. Calem, Glenn B. Canner, The Effects of the Community Reinvestment Act on Local Communities, Division of Research and Statistics, Board of Governors of the Federal Reserve System, March 20, 2003.
  9. ^ "FIRST UNION CAPITAL MARKETS CORP., BEAR, STEARNS & CO. PRICE SECURITIES OFFERING BACKED BY AFFORDABLE MORTGAGES". First Union Corporation (Wachovia).
  10. ^ Russell Roberts, "How Government Stoked the Mania", Wall Street Journal, October 3, 2008].
  11. ^ Fannie Mae Announces Pilot to Purchase $2 Billion of "MyCommunityMortgage" Loans; Pilot Lenders to Customize Affordable Products For Low- and Moderate-Income Borrowers, Corporate Responsibility News, October 30, 2000.
  12. ^ Fannie Mae "MyCommunityMortgage" homepage.
  13. ^ FDIC page on Riegle-neal Interstate Banking and Branching Efficiency Act of 1994, SEC. 109. 2 D
  14. ^ "White House Press Briefing, December 8 1993". The White House.
  15. ^ William A. Niskanen, Repeal the Community Reinvestment Act, Testimony of William A. Niskanen, Chairman Cato Institute before the Subcommittee on Financial Institutions and Consumer Credit, Committee on Banking and Financial Services United States Senate, March 8, 1995.
  16. ^ Canner, Glenn (1997). "The Community Reinvestment Act and the profitability of mortgage-oriented banks". Finance and Economics Discussion Series (1997–7). Board of Governors of the Federal Reserve System. Retrieved 2008-10-01. {{cite journal}}: Unknown parameter |coauthors= ignored (|author= suggested) (help)
  17. ^ Howard Husock, America's Trillion-Dollar Housing Mistake: The Failure of American Housing Policy, Ivran R. Dee publisher, 2003, 66-67, ISBN-10: 1566635314
  18. ^ "Treasure Department Releases CRA Study". United States Department of the Treasury. April 19, 2000. {{cite web}}: Italic or bold markup not allowed in: |publisher= (help)
  19. ^ Stephen Labaton, Issue in Depth: Leading Up to the Decision on Banking Reform, Washington Post, October 23, 1999.
  20. ^ Findlaw.com, attorneys describe the 1999 Gramm-Leach-Bliley “Financial Services Modernization Act”.
  21. ^ Financial Services Modernization Act, Community Reinvestment Act Amendments in the Gramm-Leach Act, United States Senate Committee on Banking, Housing, and Urban Affairs, 1999.
  22. ^ a b Statement by President Bill Clinton at the Signing of the Financial Modernization Bill, U.S. Treasury Department Office of Public Affairs, November 12, 1999.
  23. ^ a b Press release and letter released by a contingent of "House Democrats", April 13, 2005.
  24. ^ a b FDIC Financial Institution Letters: Community Reinvestment Act Interagency Examination Procedures, April 10, 2006
  25. ^ Chairman Ben S. Bernanke , GSE Portfolios, Systemic Risk, and Affordable Housing, Speech before the Independent Community Bankers of America's Annual Convention and Techworld, Honolulu, Hawaii (via satellite), March 6, 2007.
  26. ^ Statement of Robert W. Mooney, Deputy Director, Division of Supervision and Consumer Protection, Federal Deposit Insurance Corporation on Financial Literacy and Education: The Effectiveness of Governmental and Private Sector Initiatives before the Committee on Financial Services before the U.S. House of Representatives, April 15, 2008.
  27. ^ Jeffrey W. Gunther, Should CRA Stand for “Community Redundancy Act”?, Cato Institute’s “Regulation Magazine”, Fall 2000.
  28. ^ Jeffery W. Gunther, Kelly Klemme, and Kenneth J. Robinson, “Redlining or Red Herring?”, Federal Reserve Bank of Dallas, “Southwest Economy, May/June 1999: 8.
  29. ^ a b Michelle Minton, The Community Reinvestment Act’s Harmful Legacy, How It Hampers Access to Credit, Competitive Enterprise Institute, No. 132, March 20, 2008.
  30. ^ Immergluck, Daniel (1997-10-11). "New Small Business Data Show Loans Going To Higher-Income Neighborhoods in Chicago Area". Reinvestment Alert (11). Woodstock Institute. Retrieved 2008-10-1. {{cite journal}}: Check date values in: |accessdate= (help); Unknown parameter |coauthors= ignored (|author= suggested) (help)
  31. ^ a b Stan Liebowtiz, The Real Scandal - How feds invited the mortgage mess, New York Post, February 5, 2008
  32. ^ The Effect of Consumer Interest Rate Deregulation on Credit Card Volumes, Charge-Offs, and the Personal Bankruptcy Rate, Federal Deposit Insurance Corporation "Bank Trends" Newsletter, March, 1998.
  33. ^ FDIC, Truth in Lending Act.
  34. ^ Kathleen C. Engel and Patricia A. McCoy, The CRA Implications of Predatory Lending, Fordham Urban Law Journal, Volume XXIX, April 2002.
  35. ^ Anne Kerttula, Managing Fair Lending and CRA Risk, RMA Journal, July, 2001.
  36. ^ CRA: Last-Minute Push Launched to Oppose FED, FDIC, and OCC Plans to Water Down Community Reinvestment Act Rules for 1,500 Banks, Corporate Social Responsibility News, May 5 2005.
  37. ^ Financial Institution Letters, FDIC's Supervisory Policy on Predatory Lending.
  38. ^ Paul, Ron (2008-09-23). "Commentary: Bailouts will lead to rough economic ride". CNN. Retrieved 2008-09-23.
  39. ^ "A Mortgage Fable". Wall Street Journal. 2008-09-22. Retrieved 2008-09-27.
  40. ^ Russell Roberts, "How Government Stoked the Mania," Wall Street Journal, October 3, 2008].
  41. ^ Description of Michael S. Barr, Nonresident Senior Fellow, Brookings Institute.
  42. ^ Barr, Michael. "Prepared Testimony of Michael S. Barr" (PDF). U.S. House of Representatives. {{cite web}}: Italic or bold markup not allowed in: |publisher= (help)
  43. ^ Alan M. White Valpariso University School of Law Faculty page
  44. ^ Alan M. White, Blaming the CRA, Public Citizen’s Consumer Law and Policy blog, September 23, 2008.
  45. ^ Ellis, Luci. "The housing meltdown: Why did it happen in the United States?" (PDF). BIS Working Papers (259): 5.
  46. ^ Janet L. Yellen, Janet L. Yellen (2008-3-31). "Opening Remarks to the 2008 National Interagency Community Reinvestment Conference". Federal Reserve Bank of San Francisco. Retrieved 2008-10-01. {{cite web}}: Check date values in: |date= (help)
  47. ^ Traiger & Hinckley LLP. (2008). The Community Reinvestment Act: A Welcome Anomaly in the Foreclosure Crisis.
  48. ^ Ellen Seidmen, Financial Services Policy Director at New America Foundation web site.
  49. ^ Seidman, Ellen (2008-4-15). "No, Larry, CRA Didn't Cause the Sub-Prime Mess". New America Foundation. Retrieved 2008-09-29. {{cite web}}: Check date values in: |date= (help)
  50. ^ Ellen Seidman, It's Still Not CRA, Seidman blog at New America Foundation, September 22, 2008.

External links

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