CRA Mortgages: A Failure to Implement cover image

CRA reform efforts must address the fact that federal regulators have rated 95% of banks Satisfactory or better even though data show fewer regulated lenders meeting the law’s goals.

This is the first of two reports based on Community Lending Fact Book data presented in oral form at our June Change the Map Economic Justice Awards event; the second will focus on the growing racial wealth gap in Chicago.


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Banking has changed considerably since the Community Reinvestment Act (CRA) was passed in 1977, and updates to its implementing regulation in the mid-1990s were soon outdated. In 2015 the agencies responsible for regulating banks subject to CRA requirements (CRA banks) began to update the law yet again.

This report uses Woodstock Institute’s annual Community Lending Fact Book data of mortgage lending in Chicago from 1984 to 2019 as a proxy to evaluate whether the CRA has achieved its goal of closing the gap in lending disparities. Analysis of data from those Fact Books shows some of the issues that CRA modernization needs to address. We find that:

  1. CRA banks do not meet the goal of lending to low- and moderate-income borrowers and in low- and moderate-income neighborhoods as required by the CRA.
    • CRA banks originated nearly 84% of all mortgages in 2007; by 2019 that share had dropped to just 45%. 
    • CRA banks originated mortgages of roughly the same average amount per loan as lenders not subject to CRA requirements until 2011; by 2019, the average loan amount for CRA banks was roughly $155,000 higher than the average for lenders not subject to CRA requirements.
    • CRA banks cut back on originating government-backed mortgages between 2008 and 2019, with their share of government-backed mortgage originations declining from 62% to 19%.
  2. CRA banks originated many more loans in the predominantly White Central/North region than the rest of the city, including majority communities of color, between 1984 and 2019.
    • CRA banks originated an average of 1.2 times the number of loans per 100 owner-occupied units in the Central/North region as in the rest of the city in 1984; by 2019, that had increased to 2.1 times the number of loans.
    • The average loan amount that CRA banks originated in 1984 was 3.1 times as large in the Central/North region as in the rest of the city; by 2019, the average was 4.7 times as large.
    • In 1984, CRA banks originated 49% of their mortgages, 71% of the total amount they originated, in the Central/North region that had 44% of all owner-occupied units at the time; in 2019, they originated 73% of their mortgages, 86% of the total amount they originated, in the Central/North region that then had 56% of all owner-occupied units.

The data show CRA banks originate mortgages in patterns inconsistent with the goals of the CRA, and the gap has widened substantially between 1984 and 2019. Yet over the same time period, between 90 and 95% of banks received Satisfactory or Outstanding CRA ratings from the federal bank regulators.

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