3/14/2023 0 Comments Naca budget workbook![]() ![]() Regulation prohibited savings banks from branching across state lines and sometimes even limited branching within states, inhibiting competition, the most powerful defense against discrimination. Banking in the 1970s, when CRA was passed, was a highly regulated industry in which small, local savings banks, rather than commercial banks, provided most home mortgages. ![]() None of these justifications holds up, however, because of the changes that reshaped America's banking industry in the 1990s. Going one step further, the Treasury Department recently asserted that banks that do figure out ways to reach inner-city borrowers might not be able to stop competitors from using similar methods-and therefore would not undertake such marketing in the first place without a push from Washington. They just needed a push from the law to learn how to identify profitable inner-city lending opportunities. In addition, the Act's backers claimed, CRA would be profitable for banks. Implicit in the bill's rationale was a belief that CRA was needed to counter racial discrimination in lending, an assumption that later seemed to gain support from a widely publicized 1990 Federal Reserve Bank of Boston finding that blacks and Hispanics suffered higher mortgage-denial rates than whites, even at similar income levels. CRA decreed that banks have "an affirmative obligation" to meet the credit needs of the communities in which they are chartered, and that federal banking regulators should assess how well they do that when considering their requests to merge or to open branches. The Act, which Jimmy Carter signed in 1977, grew out of the complaint that urban banks were "redlining" inner-city neighborhoods, refusing to lend to their residents while using their deposits to finance suburban expansion. The CRA's logic also helps to ensure that inner-city neighborhoods stay poor by discouraging the kinds of investment that might make them better off. As enforced today, though, the law portends just the opposite, threatening to undermine the efforts of the upwardly mobile poor by saddling them with neighbors more than usually likely to depress property values by not maintaining their homes adequately or by losing them to foreclosure. The CRA's premise sounds unassailable: helping the poor buy and keep homes will stabilize and rebuild city neighborhoods. banks have committed nearly $1 trillion for inner-city and low-income mortgages and real estate development projects, most of it funneled through a nationwide network of left-wing community groups, intent, in some cases, on teaching their low-income clients that the financial system is their enemy and, implicitly, that government, rather than their own striving, is the key to their well-being. Please Note: Digital and online products are not returnable but can be exchanged for other digital/online offerings within 10 days of purchase.The Clinton administration has turned the Community Reinvestment Act, a once-obscure and lightly enforced banking regulation law, into one of the most powerful mandates shaping American cities-and, as Senate Banking Committee chairman Phil Gramm memorably put it, a vast extortion scheme against the nation's banks. How to access your electronic publication This publication is copyrighted and purchase is good for one download/use. Compliance officers, audit personnel, and operations staff will find the Workbook a valuable tool. User-friendly worksheet questions are easily answered and include room for comments, to assist in developing a comprehensive ACH risk management program for your FI. Other enhancements include the addition of questions related to vendor oversight, Nacha's Credit-Push Fraud Risk Management Framework, internal policies related to NSF fees on re-presented transactions, as well as the Third-Party Sender and Nested Third-Party Sender obligations. The 2023 ACH Risk Assessment Workbook has been updated to delve more deeply into internal origination and Electronic Banking authentication, multi-factor authentication (MFA), and layered security controls. ![]() EPCOR's ACH Risk Assessment Workbook guides you in evaluating the FI's ACH risks by asking thought provoking questions about its current ACH policies, procedures, and processes. ![]() Individual chapters address System and Controls, Credit Risk, High-Risk Activities, Compliance Risk, Third-Party Service Providers and Nacha Risk Management, Operational and Transaction Risk, and Information Technology Risk. By answering Yes, No or Not Applicable, this workbook will identify strengths and weaknesses in your existing ACH risk management program. Content of the Workbook includes risk obligations as defined in the OCC Bulletin 2006- 39-ACH Risk Management Guidance and the FFIEC Retail Payment Systems IT Examination Handbook and current Nacha Rules. The ACH Risk Assessment Workbook is designed to assist Financial Institutions (FI), both RDFIs and ODFIs, in addressing its ACH risk. ![]()
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