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In Response To:
Thread Starter: Making me CRAzy
Title: Re: CRA public report with RESPA allegations?

Our CRA public evaluation (we got a “Satisfactory”) written by the FDIC includes extremely negative FDIC commentary that is (arguably) not relevant to our CRA evaluation, but was instead shoplifted from our compliance exam! What gives? Is that normal? Does FDIC typically comment on their critical views of your lending compliance efforts outside of CRA, in a public CRA disclosure?

Specifically, the report contains a section called “Discriminatory or Other Illegal Credit Practices” and makes the allegation that “illegal credit practices” contrary to CRA goals exist, pertaining to RESPA Section 8. I thought that findings of that nature were more or less private, between the bank and its regulator. I’m very surprised that the FDIC would have crammed this into a public CRA disclosure that we are required to share with the public upon request. I am also wondering if the fact that the bank fought these findings for 4 months played into the decision to shoehorn that comment into a CRA report.