August 14, 2024 • 16 mins
In Episode 80 of the podcast series on regulatory compliance, Len and Dean discuss the topic of redlining with Lori Sommerfield, a partner at Troutman Pepper, in a new two-part series “Red Warning on Redlining.” Lori, a seasoned fair lending attorney, explains the traditional and modern definitions of redlining, emphasizing how regulators now primarily use Home Mortgage Disclosure Act (HMDA) data to identify potential redlining activity without other evidence to support such claims. She also discusses the DOJ's "Combatting Redlining Initiative," which is a “whole of government” approach leveraging federal agencies, U.S. attorneys, and state attorneys general to eradicate redlining practices. The episode highlights the challenges financial institutions face under aggressive enforcement and the importance of monitoring for redlining risks.
Brought to you by GeoDataVision and M&M Consulting
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
(00:00):
Welcome to the Compliance 911 Show, a no-nonsense podcast discussing hot topics
for today's busy compliance professional.
It's everything you wanted to know about regulatory compliance, but were afraid to ask.
And now, here are your hosts, Dean Stockford of M&M Consulting and Len Susio of GeoData Vision.
(00:31):
Dean, I don't know about you, but I'm really looking forward to today's podcast
because we are going to be discussing something very different in this,
our 80th podcast and the 81st to follow.
We will not only be discussing the hottest regulatory topic in banking today,
redlining, we are also going to be interviewing one of the leading legal experts
(00:52):
in the field, attorney Lori Summerfield from Troutman Pepper.
Lori Summerfield is a partner in the Washington Washington, D.C.,
office of Troutman Pepper in the firm's Consumer Financial Services Practice Group.
Lori is a seasoned fair lending attorney with over 25 years of experience in
federal government, in-house, and private practice settings.
(01:14):
She has deep expertise in fair lending and responsible banking regulatory compliance,
including the Equal Credit Opportunity Act, the Fair Housing Act,
and unfair, deceptive, or abusive acts or practices laws, UDAP.
And she counsels clients in successfully navigating examinations by the CFPB
(01:34):
and the federal banking agencies and related supervisory issues.
In addition, Lori has successfully defended clients in many fair lending investigations
and enforcement actions by the U.S.
Department of Justice, the CFPB, and the federal banking agencies.
Now, because it's such a hot topic, we've decided to name this series Red Warning
(01:55):
and Red Lining, and today's episode will be called Looking Back,
while the second episode will be called Looking Forward.
Welcome to our podcast today, Lori.
Thanks, Lynn. I'm happy to be here with you and Dean. Great.
Well, I know this is going to be a really interesting discussion today.
So let's start with some history on redlining and what's going on today.
(02:16):
Now, redlining has traditionally been defined as avoiding marketing or lending
in urban areas with a majority-minority population.
But regulators have now begun focusing on, quote, modern-day redlining in the
digital era. Sarah, can you explain how regulators are now defining redlining
violations and how that may differ from historical practice? Sure, Len.
(02:39):
Over the past few years, regulators have brought redlining cases without establishing
that a bank intentionally avoided lending in a minority neighborhood.
Instead, regulators now rely almost exclusively on statistics based on the Home
Mortgage Disclosure Act data to look for indirect or circumstantial evidence of redlining.
(03:00):
Rather than using statistics plus other factors, as they've done in the past.
So federal agencies do this by comparing the number of mortgage applications
received by a bank from majority minority census tracts to the total number
of applications that the bank receives, and then comparing the bank's statistics to its peers.
(03:20):
Now, peers are determined by regulators as other mortgage lenders that have
50 percent to 200 percent of the mortgage loan volume of the bank,
even if they're not the same type of charter.
And regulators' determination of peers is often different than the bank's,
which is problematic, of course.
So, for example, a federal agency will compare a community bank to a mega bank
(03:43):
and non-bank mortgage lenders that do business in its market.
If the regulators see any statistically significant difference between the bank's
statistics and its peers, no matter how small, the regulators will conduct a
redlining investigation investigation and might even possibly bring a redlining
enforcement action on that basis.
This tactic, when it's combined with the highly aggressive enforcement approach
(04:07):
that we're seeing in the current regulatory environment,
means that many banks are being accused of redlining practices by their regulator,
even if there's no other evidence of redlining beyond statistical analysis results.
And regulators are required under their own fair lending exam procedures to
look for other factors that would either support or refute a finding of redlining.
(04:29):
But that simply isn't occurring in this regulatory environment.
We've heard a lot about combating the redlining initiative, Lori.
Can you explain the combating redlining initiative? What is it and how is it being enforced? worst?
Of course, Dean. The Combating Redlining Initiative was announced by DOJ in
(04:51):
October of 2021 at a major press conference, and it's one of President Biden's
signature regulatory efforts.
The initiative is being undertaken by DOJ in conjunction with other federal
regulators, and that includes the federal banking agencies, the CFPB,
and HUD as a whole-of-government approach to eradicating redlining practices.
(05:13):
The federal government is also partnering with U.S. attorneys' offices and increasing
coordination efforts with state attorneys general across the U.S.
By using them as what they call force multipliers to accomplish the goals of
the combating redlining initiatives.
It's really quite unprecedented, and we've never seen anything quite like it.
Yeah, that's certainly been my experience for sure. How do bank regulators coordinate
(05:38):
with the Department of Justice? That's a good question, Dean.
Under the federal fair lending laws, if the federal banking agencies or the
CFPB have a quote unquote reason to believe, close quote, that a bank has engaged
in a pattern or practice of fair lending violations,
and of course that includes redlining,
(05:58):
they're required to refer the matter to DOJ.
Under the Equal Credit Opportunity Act. And if the matter involves a Fair Housing
Act violation, as redlining allegations do, then the agency must also notify HUD.
Now, DOJ can either accept the referral and proceed to investigate and potentially
prosecute the case, or DOJ can return the referral to the federal banking agencies or the Bureau.
(06:23):
If the case is returned, the federal banking agency or the CFPB can still pursue
their own enforcement action against the bank, however.
So banks can be subject to enforcement either by the DOJ based on a referral
or if the case is returned by the agency itself.
I also want to note that because of the political pressure of this combating
(06:45):
redlining initiative, the federal agencies are highly incentivized to make as
many referrals to DOJ as possible.
And if you want to get a sense of some of the numbers, I would suggest taking a look
at the CFPB's most recent fair lending report to Congress that enumerates the
referrals that have been made by the federal banking agencies and the CFPB under ACOA to DOJ.
(07:09):
The numbers are a little bit difficult to discern because they're sometimes
mixed in with other ACOA referrals to DOJ, but it's rather enlightening to see
how vastly the numbers of referrals have increased since 2021.
That's great advice. And I certainly think it would be interesting to look at for sure.
So what are some of the common elements of redlining cases that the federal agencies have brought?
(07:35):
Well, first of all, let me note that some of the cases that are being brought
by the federal agencies are either traditional redlining cases,
you know, where you have an allegation that a bank intentionally avoided a minority
neighborhood that is typically in an urban core.
It's kind of that concept of, you know, drawing a red line on a map and creating
(07:57):
like a donut around minority neighborhoods that an institution doesn't want to serve.
But then there's also the modern day types of claims that we're seeing that,
again, are based almost exclusively on HMDA data statistics.
It's really hard to outline everything in the brief amount of time that we have in a podcast,
but two common elements that we've seen since 2021 when the Combating Redlining
(08:22):
Initiative was announced is sometimes lenders were aware of redlining risks,
sometimes for years, without taking corrective action, or they weren't doing,
you know, effective or ongoing redlining analyses.
And sometimes we see evidence of discrimination in either employee or manager
emails through disparaging descriptions of certain neighborhoods or overt hostility
(08:46):
toward members of protected class groups.
And one case I think that exemplifies this quite well is the CFPB's case against
Townstone Financial, which was a non-bank mortgage lender in the Chicago area. you.
So I'll just leave it at that for now.
Excellent. What were the typical vulnerabilities of these financial institutions?
(09:10):
And for example, did they lack a process to monitor or, you know,
obviously it's a control breakdown, but did they, what did they,
what did they have or what were they vulnerable for relative to these redlining complaints? point?
Often we see that the regulators are alleging that the bank failed to provide
adequate fair lending oversight.
They lacked a robust fair lending risk management program, in particular,
(09:35):
that was designed to detect redlining risk.
Sometimes banks fail to monitor redlining risk entirely, or they do so in an inadequate way.
Or in some cases, banks can be conducting fair lending and redlining analyses,
but then not take corrective action when they see warning signs of risk.
So that's why it's important to work with legal counsel and qualified statisticians
(09:59):
or econometricians who know how to do appropriate redlining analyses and to
promptly follow up with corrective action when redlining risk is detected.
Lori, the concept of, quote, a reasonably expected market area,
also known as a REMA, it's a critical factor when evaluating whether redlining practices exist.
What are the guidelines used by the regulators when determining how a REMA is
(10:23):
delineated in each situation?
And how can the configuration of a REMA affect potential redlining outcomes?
That's a really good question, Len. And as you and I know, since we've worked
together on a couple of cases,
REMA is really a critical factor in many of these cases that,
depending on how the REMA is determined and configured can really produce an
(10:44):
adverse outcome for a bank.
So let me just give a little bit of background on REMA first.
The concept of REMA has been around for about 15 years, but it's not a creation
of law or regulation or even regulatory guidance.
Instead, the concept emanates from the federal banking agencies and the CFPB's
fair lending exam procedures.
(11:06):
And under those procedures, examiners are permitted to define a bank's REMA
as they deem appropriate.
Here's how it works. When examiners assess a bank's decisions about how much
access to credit to provide to various geographical areas,
they believe the areas for which those decisions can best be compared are areas
where the institution actually marketed and provided credit.
(11:28):
So that's typically a bank's CRA assessment area versus where the bank could
reasonably expected to have marketed and provided credit.
And that, of course, is the REMA.
For that reason, a REMA might be defined to go beyond a bank CRA assessment
area because an examiner may determine that an assessment area is too limiting
(11:49):
in terms of evaluating redlining risk.
And I'd also like to note that examiners often define REMA in a way that's not
the same as the bank CRA assessment area.
And subjective approach often results in an arbitrary after-the-fact determination
by the primary federal regulator about what a bank's REMA should be.
(12:10):
And it's basically kind of a gotcha mentality or approach rather than collaboratively
working with banks in advance to determine what the bank's appropriate REMA should be.
So again, sort of circling back to my comment at the top of this answer,
depending on how a REMA is defined,
it can either be helpful to a bank if the examiner determines that the bank's
(12:33):
REMA is the same as its CRA assessment area because the bank's already serving
that community, or it can be adverse.
So, for example, if the REMA is defined to include an area larger than the bank's
CRA assessment area and the bank is unaware of it, that can sometimes result
in a misleading appearance of potential redlining to the regulator.
(12:54):
So the REMA really affects everything, the fair lending statistical analysis
that is conducted based on HMDA data, peer analyses, et cetera.
So it's critically important.
Len, you might have some comments or some insight on this issue,
too, because I know you deal with REMA issues all the time in your practice. Yes.
(13:15):
And Lori, you hit the nail on the head. It's probably the most important factor
in redlining cases because how you define the market that's being used as the
basis for redlining affects everything.
Like you just said, it affects the bank's penetration rates in the minority tracks.
It affects the market data as well. It affects who the peers are.
(13:37):
And I have found that in many cases, the regulators are adopting an expansive
concept of what the REIM is,
frequently going way beyond the bank's CRA assessment area to a point where
I think it's unrealistic.
And I'll make a very quick comment here.
For years, they gave webinars about how they did this.
(14:00):
And they looked at these factors like you were identifying before,
you know, where banks marketing, they backed the geographic dispersion of the
banks, lending, et cetera.
But they announced shortly after the combat and redlining initiative,
they were changing that approach.
I'm talking about the regulators, of course, that they're looking at something,
something that MSAs and metropolitan divisions in their entirety.
(14:22):
Now for B of A and Wells Fargo and other mega institutions, that's not going
to be a problem in most cases.
But for community banks, this could be a real problem because it results in
an unrealistic market and an unrealistic market means unrealistic comparisons.
And you and I have been in a couple of situations where we've seen regulators do exactly that.
(14:43):
They mandated that the REMA was in one case, 600% bigger, six times larger than
the bank's series assessment area. The other one.
It was a community bank that they basically said, the counties you've been serving
are only part of the MSA. We're going to look at your performance in the entire MSA.
And in that particular situation, all the minority tracks were in the part of
(15:06):
the MSA that was not in the bank's assessment area. So we saw the result of that.
It was the conclusion was preordained by the definition of the REMA.
So this is a really big glory. Lori. We could do an entire session just on that
topic, in my opinion, as well.
So true, Len, and your commentary is spot on.
(15:27):
Well, Lori, this has been very informative as part one, looking back on redlining
history of our two-part series on redlining.
Thank you for educating our audience today. I can't wait for our next discussion
looking ahead. Where is redlining headed?
This is Len Susio from GeoDataVision. And this is Dean Stockford from M&M Consulting
(15:48):
saying thank you to Lori Summerfield for joining us today and to you,
our listeners, for tuning into today's very, very, very informative discussion.
Please let us know of any additional topics you would like to hear in future episodes.
Thanks for listening to the Compliance 911 Show. If you like the podcast,
be sure to subscribe so you don't miss an episode.
(16:09):
While you're at it, please give us a like and review to help others find the
show. As always, links are in the show notes and you can always find us online
at compliance911show.com.
Follow M&M Consulting and Geo Data Vision on LinkedIn for all the latest news
and information on compliance hot topics.
(16:33):
Music.
Welcome to the Compliance 911 Show, a no-nonsense podcast discussing hot topics
for today's busy compliance professional.
It's everything you wanted to know about regulatory compliance, but were afraid to ask.
And now, here are your hosts, Dean Stockford of M&M Consulting and Len Susio of GeoData Vision.
(00:31):
Dean, I don't know about you, but I'm really looking forward to today's podcast
because we are going to be discussing something very different in this,
our 80th podcast and the 81st to follow.
We will not only be discussing the hottest regulatory topic in banking today,
redlining, we are also going to be interviewing one of the leading legal experts
(00:52):
in the field, attorney Lori Summerfield from Troutman Pepper.
Lori Summerfield is a partner in the Washington Washington, D.C.,
office of Troutman Pepper in the firm's Consumer Financial Services Practice Group.
Lori is a seasoned fair lending attorney with over 25 years of experience in
federal government, in-house, and private practice settings.
(01:14):
She has deep expertise in fair lending and responsible banking regulatory compliance,
including the Equal Credit Opportunity Act, the Fair Housing Act,
and unfair, deceptive, or abusive acts or practices laws, UDAP.
And she counsels clients in successfully navigating examinations by the CFPB
(01:34):
and the federal banking agencies and related supervisory issues.
In addition, Lori has successfully defended clients in many fair lending investigations
and enforcement actions by the U.S.
Department of Justice, the CFPB, and the federal banking agencies.
Now, because it's such a hot topic, we've decided to name this series Red Warning
(01:55):
and Red Lining, and today's episode will be called Looking Back,
while the second episode will be called Looking Forward.
Welcome to our podcast today, Lori.
Thanks, Lynn. I'm happy to be here with you and Dean. Great.
Well, I know this is going to be a really interesting discussion today.
So let's start with some history on redlining and what's going on today.
(02:16):
Now, redlining has traditionally been defined as avoiding marketing or lending
in urban areas with a majority-minority population.
But regulators have now begun focusing on, quote, modern-day redlining in the
digital era. Sarah, can you explain how regulators are now defining redlining
violations and how that may differ from historical practice? Sure, Len.
(02:39):
Over the past few years, regulators have brought redlining cases without establishing
that a bank intentionally avoided lending in a minority neighborhood.
Instead, regulators now rely almost exclusively on statistics based on the Home
Mortgage Disclosure Act data to look for indirect or circumstantial evidence of redlining.
(03:00):
Rather than using statistics plus other factors, as they've done in the past.
So federal agencies do this by comparing the number of mortgage applications
received by a bank from majority minority census tracts to the total number
of applications that the bank receives, and then comparing the bank's statistics to its peers.
(03:20):
Now, peers are determined by regulators as other mortgage lenders that have
50 percent to 200 percent of the mortgage loan volume of the bank,
even if they're not the same type of charter.
And regulators' determination of peers is often different than the bank's,
which is problematic, of course.
So, for example, a federal agency will compare a community bank to a mega bank
(03:43):
and non-bank mortgage lenders that do business in its market.
If the regulators see any statistically significant difference between the bank's
statistics and its peers, no matter how small, the regulators will conduct a
redlining investigation investigation and might even possibly bring a redlining
enforcement action on that basis.
This tactic, when it's combined with the highly aggressive enforcement approach
(04:07):
that we're seeing in the current regulatory environment,
means that many banks are being accused of redlining practices by their regulator,
even if there's no other evidence of redlining beyond statistical analysis results.
And regulators are required under their own fair lending exam procedures to
look for other factors that would either support or refute a finding of redlining.
(04:29):
But that simply isn't occurring in this regulatory environment.
We've heard a lot about combating the redlining initiative, Lori.
Can you explain the combating redlining initiative? What is it and how is it being enforced? worst?
Of course, Dean. The Combating Redlining Initiative was announced by DOJ in
(04:51):
October of 2021 at a major press conference, and it's one of President Biden's
signature regulatory efforts.
The initiative is being undertaken by DOJ in conjunction with other federal
regulators, and that includes the federal banking agencies, the CFPB,
and HUD as a whole-of-government approach to eradicating redlining practices.
(05:13):
The federal government is also partnering with U.S. attorneys' offices and increasing
coordination efforts with state attorneys general across the U.S.
By using them as what they call force multipliers to accomplish the goals of
the combating redlining initiatives.
It's really quite unprecedented, and we've never seen anything quite like it.
Yeah, that's certainly been my experience for sure. How do bank regulators coordinate
(05:38):
with the Department of Justice? That's a good question, Dean.
Under the federal fair lending laws, if the federal banking agencies or the
CFPB have a quote unquote reason to believe, close quote, that a bank has engaged
in a pattern or practice of fair lending violations,
and of course that includes redlining,
(05:58):
they're required to refer the matter to DOJ.
Under the Equal Credit Opportunity Act. And if the matter involves a Fair Housing
Act violation, as redlining allegations do, then the agency must also notify HUD.
Now, DOJ can either accept the referral and proceed to investigate and potentially
prosecute the case, or DOJ can return the referral to the federal banking agencies or the Bureau.
(06:23):
If the case is returned, the federal banking agency or the CFPB can still pursue
their own enforcement action against the bank, however.
So banks can be subject to enforcement either by the DOJ based on a referral
or if the case is returned by the agency itself.
I also want to note that because of the political pressure of this combating
(06:45):
redlining initiative, the federal agencies are highly incentivized to make as
many referrals to DOJ as possible.
And if you want to get a sense of some of the numbers, I would suggest taking a look
at the CFPB's most recent fair lending report to Congress that enumerates the
referrals that have been made by the federal banking agencies and the CFPB under ACOA to DOJ.
(07:09):
The numbers are a little bit difficult to discern because they're sometimes
mixed in with other ACOA referrals to DOJ, but it's rather enlightening to see
how vastly the numbers of referrals have increased since 2021.
That's great advice. And I certainly think it would be interesting to look at for sure.
So what are some of the common elements of redlining cases that the federal agencies have brought?
(07:35):
Well, first of all, let me note that some of the cases that are being brought
by the federal agencies are either traditional redlining cases,
you know, where you have an allegation that a bank intentionally avoided a minority
neighborhood that is typically in an urban core.
It's kind of that concept of, you know, drawing a red line on a map and creating
(07:57):
like a donut around minority neighborhoods that an institution doesn't want to serve.
But then there's also the modern day types of claims that we're seeing that,
again, are based almost exclusively on HMDA data statistics.
It's really hard to outline everything in the brief amount of time that we have in a podcast,
but two common elements that we've seen since 2021 when the Combating Redlining
(08:22):
Initiative was announced is sometimes lenders were aware of redlining risks,
sometimes for years, without taking corrective action, or they weren't doing,
you know, effective or ongoing redlining analyses.
And sometimes we see evidence of discrimination in either employee or manager
emails through disparaging descriptions of certain neighborhoods or overt hostility
(08:46):
toward members of protected class groups.
And one case I think that exemplifies this quite well is the CFPB's case against
Townstone Financial, which was a non-bank mortgage lender in the Chicago area. you.
So I'll just leave it at that for now.
Excellent. What were the typical vulnerabilities of these financial institutions?
(09:10):
And for example, did they lack a process to monitor or, you know,
obviously it's a control breakdown, but did they, what did they,
what did they have or what were they vulnerable for relative to these redlining complaints? point?
Often we see that the regulators are alleging that the bank failed to provide
adequate fair lending oversight.
They lacked a robust fair lending risk management program, in particular,
(09:35):
that was designed to detect redlining risk.
Sometimes banks fail to monitor redlining risk entirely, or they do so in an inadequate way.
Or in some cases, banks can be conducting fair lending and redlining analyses,
but then not take corrective action when they see warning signs of risk.
So that's why it's important to work with legal counsel and qualified statisticians
(09:59):
or econometricians who know how to do appropriate redlining analyses and to
promptly follow up with corrective action when redlining risk is detected.
Lori, the concept of, quote, a reasonably expected market area,
also known as a REMA, it's a critical factor when evaluating whether redlining practices exist.
What are the guidelines used by the regulators when determining how a REMA is
(10:23):
delineated in each situation?
And how can the configuration of a REMA affect potential redlining outcomes?
That's a really good question, Len. And as you and I know, since we've worked
together on a couple of cases,
REMA is really a critical factor in many of these cases that,
depending on how the REMA is determined and configured can really produce an
(10:44):
adverse outcome for a bank.
So let me just give a little bit of background on REMA first.
The concept of REMA has been around for about 15 years, but it's not a creation
of law or regulation or even regulatory guidance.
Instead, the concept emanates from the federal banking agencies and the CFPB's
fair lending exam procedures.
(11:06):
And under those procedures, examiners are permitted to define a bank's REMA
as they deem appropriate.
Here's how it works. When examiners assess a bank's decisions about how much
access to credit to provide to various geographical areas,
they believe the areas for which those decisions can best be compared are areas
where the institution actually marketed and provided credit.
(11:28):
So that's typically a bank's CRA assessment area versus where the bank could
reasonably expected to have marketed and provided credit.
And that, of course, is the REMA.
For that reason, a REMA might be defined to go beyond a bank CRA assessment
area because an examiner may determine that an assessment area is too limiting
(11:49):
in terms of evaluating redlining risk.
And I'd also like to note that examiners often define REMA in a way that's not
the same as the bank CRA assessment area.
And subjective approach often results in an arbitrary after-the-fact determination
by the primary federal regulator about what a bank's REMA should be.
(12:10):
And it's basically kind of a gotcha mentality or approach rather than collaboratively
working with banks in advance to determine what the bank's appropriate REMA should be.
So again, sort of circling back to my comment at the top of this answer,
depending on how a REMA is defined,
it can either be helpful to a bank if the examiner determines that the bank's
(12:33):
REMA is the same as its CRA assessment area because the bank's already serving
that community, or it can be adverse.
So, for example, if the REMA is defined to include an area larger than the bank's
CRA assessment area and the bank is unaware of it, that can sometimes result
in a misleading appearance of potential redlining to the regulator.
(12:54):
So the REMA really affects everything, the fair lending statistical analysis
that is conducted based on HMDA data, peer analyses, et cetera.
So it's critically important.
Len, you might have some comments or some insight on this issue,
too, because I know you deal with REMA issues all the time in your practice. Yes.
(13:15):
And Lori, you hit the nail on the head. It's probably the most important factor
in redlining cases because how you define the market that's being used as the
basis for redlining affects everything.
Like you just said, it affects the bank's penetration rates in the minority tracks.
It affects the market data as well. It affects who the peers are.
(13:37):
And I have found that in many cases, the regulators are adopting an expansive
concept of what the REIM is,
frequently going way beyond the bank's CRA assessment area to a point where
I think it's unrealistic.
And I'll make a very quick comment here.
For years, they gave webinars about how they did this.
(14:00):
And they looked at these factors like you were identifying before,
you know, where banks marketing, they backed the geographic dispersion of the
banks, lending, et cetera.
But they announced shortly after the combat and redlining initiative,
they were changing that approach.
I'm talking about the regulators, of course, that they're looking at something,
something that MSAs and metropolitan divisions in their entirety.
(14:22):
Now for B of A and Wells Fargo and other mega institutions, that's not going
to be a problem in most cases.
But for community banks, this could be a real problem because it results in
an unrealistic market and an unrealistic market means unrealistic comparisons.
And you and I have been in a couple of situations where we've seen regulators do exactly that.
(14:43):
They mandated that the REMA was in one case, 600% bigger, six times larger than
the bank's series assessment area. The other one.
It was a community bank that they basically said, the counties you've been serving
are only part of the MSA. We're going to look at your performance in the entire MSA.
And in that particular situation, all the minority tracks were in the part of
(15:06):
the MSA that was not in the bank's assessment area. So we saw the result of that.
It was the conclusion was preordained by the definition of the REMA.
So this is a really big glory. Lori. We could do an entire session just on that
topic, in my opinion, as well.
So true, Len, and your commentary is spot on.
(15:27):
Well, Lori, this has been very informative as part one, looking back on redlining
history of our two-part series on redlining.
Thank you for educating our audience today. I can't wait for our next discussion
looking ahead. Where is redlining headed?
This is Len Susio from GeoDataVision. And this is Dean Stockford from M&M Consulting
(15:48):
saying thank you to Lori Summerfield for joining us today and to you,
our listeners, for tuning into today's very, very, very informative discussion.
Please let us know of any additional topics you would like to hear in future episodes.
Thanks for listening to the Compliance 911 Show. If you like the podcast,
be sure to subscribe so you don't miss an episode.
(16:09):
While you're at it, please give us a like and review to help others find the
show. As always, links are in the show notes and you can always find us online
at compliance911show.com.
Follow M&M Consulting and Geo Data Vision on LinkedIn for all the latest news
and information on compliance hot topics.
(16:33):
Music.
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