State Community Reinvestment Act (CRA) Legislation
Regulators and legislators are considering options to extend the reach of the Community Reinvestment Act (CRA) to independent mortgage banks (IMBs). These policy options represent a solution in search of a problem and do not recognize the incompatibility of the CRA with the business models of IMBs and their historical lending activities. Applying the Community Reinvestment Act to IMBs would be an ineffective and misguided policy choice that MBA opposes.
Independent Mortgage Banks:
- Do not have deposits to reinvest
- Do not have access to direct government support
- Already engage in sustainable lending in low- to moderate-income (LMI) communities
- Are subject to robust oversight and supervision in every state they operate as well as from federal regulators
For more information about IMBs, please download:
- MBA Works for IMBs: IMB Special Report
- Urban Institute: An Assessment of Lending to LMI and Minority Neighborhoods and Borrowers (April 2023)
- IMB Fact Sheet: Independent Mortgage Banks: Financing the American Dream
- IMB Policy Spotlight: Independent Mortgage Banks and Community Reinvestment Requirements: A Solution in Search of a Problem
- MBA White Paper: Applying CRA to Independent Mortgage Banks: An Ineffective and Misguided Policy Choice
Selected State HMDA Data Sheets of IMB Lending to LMI Borrowers
Data Sheet Available for Download
- Click State to Download Datasheet
Related State CRA News
- January 7, 2026: New York Department of Financial Services adopts final regulations to implement CRA for Independent Mortgage Banks. Compliance is expected six months after it's publication in the New York register (see page 15) on the 7th.
- October 15, 2025: MBA, NYMBA and local groups submit comments to NY Department of Financial Services on third iteration of CRA proposal.
- September 3, 2025: New York Department of Financial Services releases third re-proposal of CRA regulations for IMBs. Details available on the Department's website and in the New York State Register (see page 7).
- June 30, 2025: Companion CRA bills introduced in New Jersey (S4694 / A5957).
- June 10, 2025: Letter from MBA, California MBA, California Building Industry Association, and Leading Builders of America letter to California Senate Banking & Financial Institutions Committee opposing AB-801.
- April 2, 2025: MBA, NYMBA and local groups submit comments to NY Department of Financial Services on February 5 CRA re-proposal.
- March 11, 2025: Connecticut SB 1398 is amended to remove Independent Mortgage Banks, the remaining bill would only amend existing CRA requirements for Banks and Credit Unions. *SB 1398 ultimately failed in 2025 session)
- February 27, 2025: Connecticut introduces CRA bill (SB 1398) to amend existing Bank & Credit Union requirements as well as add Independent Mortgage Bankers to their state CRA law.
- February 18, 2025: CRA bill introduced in California (AB-801).
- February 5, 2025: CRA legislation (HB-1040) introduced in Maryland, but withdrawn by sponsor within a week (2/10/25)
- February 5, 2025: NY Department of Financial Services officially published its proposed CRA regulations in the New York State Register.
- January 22, 2025: CRA legislation (SB-119) reintroduced in Pennsylvania.
- 2021-2024 News and Activity
Related MBA Events
There are no upcoming events that meet this criteria at this time. Check back soon!
Key State CRA Statutes and Regulations for IMBs
- Massachusetts Nonbank CRA Law, Regulations, and CRA Webpage
- Illinois Nonbank CRA Law (see Article 35)
- New York Nonbank CRA Law
