LenderLogix’ Patrick O’Brien: CRA Compliance for IMBs Has Arrived. How to Do It Right.
Patrick O’Brien is CEO of Buffalo, N.Y.-based LenderLogix, a provider of mortgage point-of-sale and automation software for banks, credit unions, independent mortgage banks and brokers.
As stewards of the housing market, mortgage lenders are uniquely responsible for contributing to the well-being of the communities they serve. This has long been a statutory requirement for depository lenders via the Community Reinvestment Act.
On the other hand, independent mortgage banks have historically been exempt from CRA compliance at the federal level. However, several states like New York have implemented CRA-style regulations, creating a new standard to which mortgage lenders of all stripes must adhere.
CRA compliance is not just a regulatory checkbox; it’s a transformative opportunity to contribute to the betterment of communities. However, lenders must take a proactive approach to outreach, as well as loan program design, to ensure a measurable impact while also complying with CRA requirements.
When it comes to increasing homeownership access to underserved communities, most lenders have addressed the issue from a financing standpoint by offering down payment assistance programs or even exploring special-purpose credit programs. While these efforts help make homeownership more affordable, they only address one aspect of the larger picture.
To maximize the impact of their CRA efforts, lenders need to take it a step further and make the connection between demographics, inventory and financing. Leveraging data analytics, listing notifications and smart loan applications, lenders can not only track compliance efficiently but also actively engage with and uplift marginalized communities impacted by historical challenges like redlining.
Given today’s market and affordability challenges, a grant or down payment assistance program can often be the difference between a qualifying or non-qualifying borrower. Lenders can match their qualifying incentives with the property head-on by identifying property listings within a majority-minority or a low-to-moderate income census tract. Thus, bringing awareness of these programs to community members early on increases their ability to access the tools within their reach.
As the saying goes, you can’t manage what you don’t measure. The journey to effective CRA compliance begins with comprehensive data analytics that offers real-time insights into lenders’ processes. This approach empowers lenders to monitor CRA progress, identify areas for improvement and maintain transparency in their lending practices. By tracking lending activities in low and moderate-income areas, lenders can tangibly demonstrate their commitment to community development and social responsibility, reinforcing their positive impact on underserved neighborhoods. Furthermore, measuring and showcasing community impact through comprehensive metrics helps demonstrate compliance with both the letter and the spirit of federal and state CRA laws.
While compliance is often the baseline lenders use to determine what they have to do, going beyond mere compliance with affordable lending efforts can pay tremendous dividends. For example, tracking available listing opportunities in low- and moderate-income neighborhoods enables lenders to actively participate in community development initiatives. This type of proactive community engagement not only seamlessly aligns with the spirit of CRA regulations but also helps drive new business efforts that benefit the local community.
Historical challenges like redlining have left specific communities underserved in terms of fair and affordable credit. These historical biases are often baked into “standardized” documents and processes, like the loan application. Technology can help break down these historical barriers and promote financial inclusion.
In the digital age, accessibility is key. Providing a user-friendly digital platform that simplifies the mortgage application process and helps identify and support qualified borrowers is especially beneficial for borrowers in marginalized communities, ensuring equal opportunities for access and navigation through the mortgage lending process.
Taking a proactive approach to CRA lending is a win-win for everyone—it has a positive impact on the community and adds a new homeowner to the area. Loan officers get the boost in business they crave in today’s market, and real estate agents can cast a wider net when listing a property. Using advanced data analytics, listing notifications and smart loan applications, mortgage lenders can not only meet regulatory requirements but actively contribute to community development, ensuring a more equitable and inclusive future for all.
(Views expressed in this article do not necessarily reflect policies of the Mortgage Bankers Association, nor do they connote an MBA endorsement of a specific company, product or service. MBA NewsLink welcomes your submissions. Inquiries can be sent to Editor Michael Tucker or Editorial Manager Anneliese Mahoney.)
