Law360: Conducting a ‘Reasonably Expected Market Area’ Analysis
Understanding and analyzing a lender's "Reasonably Expected Market Area" (REMA) is more critical than ever in light of increasing regulatory scrutiny around redlining. Mitchell Sandler's latest article in Law360 delves into the concept of REMAs, outlining how regulators define them and why they play a pivotal role in identifying redlining risks. With the DOJ's aggressive enforcement under the Combating Redlining Initiative and evolving expectations from federal and state regulators, the stakes are high for lenders to proactively address potential vulnerabilities.
The piece offers practical insights for lenders on conducting periodic REMA analyses to align their practices with regulatory expectations. By mapping lending activities, evaluating peer comparisons, and considering nuanced factors like geographic boundaries and marketing efforts, institutions can identify and mitigate risks effectively. This approach not only prepares lenders for regulatory examinations but also provides a pathway for building stronger lending strategies in underserved communities.
Check out the full Law360 article HERE to explore actionable strategies and ensure your institution is well-prepared for the complexities of modern fair lending compliance.
Click here to download a PDF copy.
About the Authors
Jeremy Hochberg has 20 years of private and public sector experience in financial services. He advises banks, financial services companies, and third-party service providers on regulatory compliance and enforcement matters. Jeremy represents clients on fair lending and responsible banking issues, including matters involving claims of disparate impact; disparate treatment; and unfair, deceptive, or abusive acts or practices (UDAAP). His work in this area includes advising on underwriting, pricing, exceptions, redlining, steering, limited English proficiency, sales and marketing, artificial intelligence and machine learning, overdrafts, credit reporting, and servicing issues.
Jon Seward has nearly 25 years at the U.S. Department of Justice in the Civil Rights Division, Jon has a wealth of experience in evaluating policies and practices by lenders that have resulted in fair lending investigations and settlements. Throughout his career, Jon has been at the forefront of efforts to promote equitable access to credit for all communities. Jon’s commitment to compliance and his wealth of experience in making referral and targeting decisions have been instrumental in shaping fair lending enforcement strategies.
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