In this period of state and federal attention toward both the Community Reinvestment Act (CRA) and the effectiveness of the financial services system in serving low- and moderate-income (LMI) people and communities and people and communities of color, it is useful to explore the impact the CRA has had on this lending. One facet of this analysis is to compare the lending patterns of entities subject to the federal CRA, namely banks and thrifts, with those of lenders not subject to the statute, namely independent mortgage banks (IMBs) and credit unions. To do so, we looked at the data concerning bank, IMB, and credit union lending to LMI borrowers and neighborhoods and minority borrowers and neighborhoods, both at the national level and for several states. We provide data and analysis to inform the policy discussion.
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