Andrew L. Sandler Discussed "Trends in Redlining Analysis: Redlining, REMA and Monitoring Fair Lending to Reach Underserved Populations" at the CRA & Fair Lending Colloquium
Almost any real estate agent in the world will tell you that the three most important things about property are location, location, location! With the convergence of CRA, Fair Lending, and HMDA, we are seeing a resurgence of location or geographical based analysis. How can an institution proactively monitor for and mitigate redlining risk? How do assessment areas come in to play? How do they interact with REMA….and just what on earth is REMA anyway? The concept of “reasonably expected market area” (“REMA”) is not new; however, since regulators consider an institution’s REMA, as well as its CRA assessment area, institutions should delineate and measure both. This discussed:
- The differences between REMA and CRA assessment area.
- Principles behind defining a REMA based on the bank’s CRA Assessment Area, Trade Area and/or the geographical location of loan applications and originations for Fair Lending analyses.
- Strategies for defining and mapping a REMA.
- Defining the geographical areas for CRA performance and Fair Lending compliance.
- Performance context as it relates to the bank’s defined CRA Assessment Area, including general performance context information, as well as a discussion of loan production offices and how they are considered when evaluating CRA performance.
- Using a REMA, CRA Assessment Area, and/or a Trade Area when evaluating application and lending patterns and marketing and outreach practices throughout the Areas’ various geographies, as defined by racial and ethnic compositions.
- Using a REMA in conjunction with a redlining analysis to evaluate a bank’s lending and level of services in majority minority census tracts.