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There are GAPS in your CMS and they involve lending!

Question: 
Do you think you have gaps in your fair lending and CRA program?
Answer: 

For the past decade there has been a constant stream of enforcement actions against financial institutions for engaging in redlining. Redlining occurs when financial institution practices result in the restriction of lending in a particular geographic area, quite frequently a low-income or a high minority population area. Redlining is:

Usually cited as a fair lending violation.
Frequently listed as a weakness in a Community Reinvestment Act (CRA) management system.
Quite often listed as both a fair lending and a CRA concern.
Now there is Small Business Data Reporting

First published on 12/15/2024

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