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Financial Services Law Insights and Observations

Federal Banking Agencies Disclose Reported 2015 CRA Lending Data

CRA

Consumer Finance

On August 18, the OCC, the FDIC, and the Federal Reserve announced the availability of a 2015 data fact sheet on small business, small farm, and community development lending as reported by certain commercial banks and savings associations pursuant to the Community Reinvestment Act (CRA). Less comprehensive than the data reported pursuant to the Home Mortgage Disclosure Act, the CRA data includes the number and dollar amount of community development loans and small business and small farm loans originated or purchased. It also indicates whether a small business or farm loan is extended to a borrower with yearly revenues of $1 million or less and combines those loans into three categories based on size, which are reported at a census tract level. CRA data does not cover loan applications that were denied or applicant demographic information, and it is not completed on a loan-by-loan basis. According to the data fact sheet, “caution should be used in drawing conclusions from analyses using only CRA data, as differences in loan volume across areas may reflect differences in local demand for credit.”