CRA- First-time Home-buyer Clinic

Posted By: Norman Paperman

CRA- First-time Home-buyer Clinic - 12/16/19 07:37 PM

Hi Kids,

Management wants me to find out if we can count a first-time home-buyer clinic for CRA. I've gone through the Q&A and have determined that unless I can qualify the participants or target audience as LMI, the answer would on it's face be a "no".

Prove me wrong?

Any ideas on how I could document a target audience that would work for CRA? We are trying to set up ad metrics on FB for a targeted ad, but that's not working real well.

Help me help them.
Posted By: Lori01

Re: CRA- First-time Home-buyer Clinic - 12/16/19 09:05 PM

Be very careful about ad metrics on FB when it comes to home loans.....your CRA auditor might not care but your fair lending auditor will have an aneurysm. (most fun I ever had during an exam was watching a 20-something trainee try to explain FB to a 50 something auditor)
Posted By: Norman Paperman

Re: CRA- First-time Home-buyer Clinic - 12/16/19 09:45 PM

I am the auditor. What would be the issue with the FB metrics? We were going to try and set an income level that matched our LMI levels in the area. We have found out that that's not an option.
Posted By: Kathleen O. Blanchard

Re: CRA- First-time Home-buyer Clinic - 12/17/19 01:09 PM

FB has been in a world of hurt for targeted lending ads....partly because even if you establish your audience legally, FB then further filters who gets to see your ad. FB is pulling back on how you can adjust and how they can adjust. I don't agree with all of the issues stated because even in non FB advertising you do not have to reach every potential customer in every ad, just present to all over your series of ads. But the part about FB controlling who gets to see ads, and preventing certain people from seeing them, is problematic. They (FB) should have learned the rules before allowing financial institution advertising and putting their algorithms to work.

Ignoring FB, how are you promoting the clinic? To what groups, through what ads (again ignoring FB?) Can you show that the content and marketing would be geared to LMI? What tract income areas are you focusing on? It is usually not too hard to get credit for first time home buyer training.
Posted By: rlcarey

Re: CRA- First-time Home-buyer Clinic - 12/18/19 02:19 PM

Timely article: https://www.federalreserve.gov/publ...umer-compliance-supervision-bulletin.pdf
Posted By: Kathleen O. Blanchard

Re: CRA- First-time Home-buyer Clinic - 12/18/19 08:45 PM

One of the good things under the CRA NPR is that financial literacy would count for all audiences.