Alston & Bird Consumer Finance ABstract

Caroline Eisner

About Caroline Eisner

Caroline Eisner is counsel in the Financial Services & Products Group. She focuses her practice on regulatory and enforcement matters, which include issues involving the Community Reinvestment Act (CRA), Fair Housing Act (FHA), and Equal Credit Opportunity Act (ECOA). She advises clients on responding to allegations of discriminatory or unfair lending practices, including redlining and reverse redlining, and assists clients to design and implement preventative and detective controls to help avoid such claims.

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CFPB Issues Special Edition of Supervisory Highlights Focusing on Junk Fees

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A&B ABstract: In the 29nd edition of its Supervisory Highlights, the Consumer Financial Protection Bureau (“CFPB”) focused on the impact of so-called “junk” fees in the mortgage servicing, auto servicing, and student loan servicing industries, among others. CFPB Issues New Edition of Supervisory Highlights: On March 8, the CFPB published a special edition of its […]

Merrily the State CRAs Roll Along

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A&B ABstract: While we wait on the final interagency rule from the Federal Reserve, OCC, and FDIC, Illinois and New York are continuing along with their state Community Reinvestment Acts (CRA). Illinois CRA Developments Illinois announced that it would hold public hearings, two on March 2, 2023 and a third on March 8, 2023, to […]

Illinois Proposes Rules Implementing Its Community Reinvestment Act for Banks, Mortgage Lenders, and Credit Unions

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A&B ABstract: The Illinois Department of Financial and Professional Regulation (“IDFPR”) has issued a notice of proposed rules to implement the newly passed Illinois Community Reinvestment Act (“ILCRA”), aimed at serving the credit needs of low- and moderate-income communities and individuals.  The proposal includes a separate set of rules applicable to state-chartered banks, non-depository mortgage […]

Is the DOJ (De Facto) Enforcing the Community Reinvestment Act?

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A&B Abstract: Furthering the Justice Department’s Combating Redlining Initiative, the Department of Justice has announced another redlining settlement.  But this settlement is different – this one involves a bank that has received top marks by its prudential regulator, the Federal Deposit Insurance Corporation (FDIC), for its compliance with the Community Reinvestment Act (CRA), a statute […]

State Community Reinvestment Acts Reaching Beyond Banks

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A&B ABstract: When Congress passed the federal Community Reinvestment Act (“CRA”) in 1977 to address redlining, it imposed affirmative requirements on insured depository institutions to serve the credit needs of the communities where they receive deposits. At that time, banks were extending the vast majority of mortgages nationally. However, non-banks have become the dominant mortgage […]