Use IXI™ Data to meet your CRA/MMCT/Fair Lending Goals

Meet your goals through a higher acceptance rate by leveraging proprietary IXI™ Data Solutions from Equifax.

Recent legislative changes have resulted in many banks scrambling to adhere to new lending guidelines.

Community Reinvestment Act (CRA)

In March 2020, The Federal Reserve Board, the FDIC, and the Office of the Comptroller of the Currency issued a joint statement encouraging financial institutions to work with customers and communities adversely affected by COVID-19, particularly those that are low- and moderate-income.

Included in the statement:

  • Pursuant to the CRA, the agencies will favorably consider retail banking services and retail lending activities in a financial institution’s assessment areas that are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected by COVID-19 consistent with safe and sound banking practices.
  • In light of the declaration of a national emergency, the attached interagency statement clarifies that financial institutions will receive CRA consideration for community development (CD) activities.
  • Qualifying CD activities include those that help to revitalize or stabilize low- or moderate-income geographies as well as distressed underserved non-metropolitan middle income geographies, and that support community services targeted to low- or moderate-income individuals.
  • Favorable consideration will be given to CD activities located in a broader statewide or regional area that includes a bank’s CRA Assessment Area and that help to stabilize communities affected by the COVID-19, provided that such institutions are responsive to the CD needs and opportunities that exist in their own assessment area(s).

Read the complete interagency joint statement here.

Fair Lending

The Consumer Financial Protection Bureau (CFPB) is emphasizing regulation and enforcement of equity issues and anti-discrimination laws, such as the Equal Credit Opportunity Act (ECOA) and the Fair Housing Act (FHA). These concerted efforts include several new fair lending policy initiatives and rule changes to promote equity and equality in banking and a renewed focus on combatting redlining. It is critical that institutions act proactively to prepare for the renewed focus on fair lending and redlining.

The Banking Law Journal outlined three key takeaways for financial institutions:

  • We expect to see an uptick in enforcement actions under this revived disparate impact theory in 2022, and institutions should be prepared for their lending practices to be assessed under this approach.
  • Institutions should proactively assess the communities they serve and consider adopting formal Limited English Proficiency (LEP) policies and procedures to provide that they are meeting the needs of those communities.
  • Financial institutions must review and revise their policies and procedures to incorporate the expanded definition of sex under Equal Credit Opportunity Act (ECOA) and Regulation B and continue to monitor interpretations and rules to keep their policies up to date.

We understand there is uncertainty about how governing bodies will administer and implement the new guidelines. However, we do know that this emphasized regulation and enforcement will likely impact your current marketing efforts.

That’s where we can help.

By leveraging Equifax’s proprietary IXI™ data, your bank’s marketers can gain a more complete picture of households’ financial and economic positions with access to aggregated, anonymous consumer asset data that has been combined with additional measures of income, discretionary spending, and credit.

This non-FCRA regulated proprietary data, which can be used in unlimited ITA campaigns for 12 months, empowers you to improve your ROI by spending your marketing dollars on consumers within a census tract who are more likely to respond to your offer, resulting in more booked loans.

IXI™ Data + Equifax Data-driven Marketing Solutions = a more focused marketing spend

Better insights through IXI™ data help drive higher ROI and reach your CRA/MMCT/Fair Lending goals by helping you to:

  • better understand which geographical areas provide the best opportunity for growth.
  • identify customers with the highest potential for growth.
  • market to customers who are a prime audience for specific products.

As a member of The IXI™ Network, you can leverage ~$27T in actual deposit account and investment position data and gain insights on data for more than 500 million accounts and one billion investment positions.

Although satisfying enhanced CRA/MMCT/Fair Lending guidance might seem overwhelming, our market and industry experts are here to help.

So, reach out today to learn more about how Equifax and Confluent Strategies can help you reach your goals.