A&B ABstract: As recently reported by the Financial Times, banks are preparing for the “deepest job cuts since the financial crisis,” with firings to be “super brutal.” Already, nonbank lenders and service providers have been suffering with several rounds of layoffs and, potentially, more to come. Former employees, particularly disgruntled ones, may have information they […]
DOJ
Is the DOJ (De Facto) Enforcing the Community Reinvestment Act?
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 […]
CFPB and DOJ Announce Redlining Settlement Against Non-Bank Mortgage Lender
A&B Abstract: On July 27, 2022, the Consumer Financial Protection Bureau (“CFPB”) and the US Department of Justice (“DOJ”) entered into a settlement with Trident Mortgage Company (“Trident”), resolving allegations under the Equal Credit Opportunity Act (“ECOA”) and the Fair Housing Act that the non-bank mortgage lender intentionally discriminated against majority-minority neighborhoods in the greater […]
Modern-Day Redlining Enforcement: A New Baseline
On October 22, 2021, the U.S. Department of Justice (DOJ) announced an aggressive new initiative, in collaboration with U.S. Attorneys’ Offices throughout the country, to combat the practice of redlining. Three days prior, the Consumer Financial Protection Bureau (CFPB) was said to be hiring up to 30 new enforcement attorneys to focus on redlining and […]
DOJ Issues Third Iteration of Its Corporate Compliance Guidance
The Department of Justice’s Criminal Division began June 2020 by issuing revisions to its Evaluation of Corporate Compliance Programs guidance. First published in 2017, and later updated in April 2019, the guidance provides insight into how the Criminal Division assesses a company’s compliance program. Further, it allows companies to proactively implement and strengthen compliance programs to align closely with […]