Wednesday, December 6, 2023

What's Up Next? SECU CEO Vows To Lead Lending Staff Forward In Expansion Of RBL To Member Mortgage And Home Equity Loans

"The Social Structure of Mortgage Discrimination"[Full article link here]

✅ The authors are academics from MIT, Princeton, Brigham Young, (2017)

 https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEhhAGzmTWoUZ3ps7qrqQ_MlwY2rnIO8incp03tUPbls-8NonYHMLdJ0_XE7ydMqfROdboxZoo3rAfsTzFh0-_KQNK4PXLu_Dz8LPPKvlMp7rZ5b74l26VGGZgB7Ul0gNe-UalKxtMRTePkm/s1600/Homeseekers+House+Word+Cloud+CURRENT_0.png

Racial disparities in wealth are currently at their widest levels in decades [more so in 2023!]. According to the , the wealth of the median white household stood at $141,900 in 2013, 13 times greater than that of the median black household ($11,000) and ten times that of the median Latino household ($13,700). These gaps in wealth by race are less a product of income disparities than of differential access to good homes in high quality neighborhoods, which in turn produces racial differences in home ownership rates, home values, and the accumulation of home equity, the principal source of wealth for most American families ().

Historically, these disparities have been driven by multiple forms of discrimination, both public and private, including white mob violence against African-Americans trying to move into formerly all-white neighborhoods, municipal segregation ordinances prohibiting residence by blacks on predominantly white blocks, racially restrictive covenants barring the future sale of a property to non-whites. One of the many forms of neighborhood-based racial discrimination that contributed to current disparities is the legacy of redlining—the denial of credit to non-white residential areas (Rothstein 2017). More recently, the rise of new lending practices that specifically target nonwhite neighborhoods for risky, high cost financial services have further widened racial disparities in home equity and wealth (; ; ; ; ).

Numerous quantitative studies have found that black and Latino borrowers over the past decade were frequently charged more for mortgage loans than similarly situated white borrowers (e.g. Bayer, Ferreira, and Ross, 2015; ; ; Courchane, 2007; ). Even after controlling for credit scores, loan to value ratios, the existence of subordinate liens, and housing and debt expenses relative to individual income, Bayer, Ferreira, and Ross (2015) found that black and Latino borrowers in all of the seven metropolitan areas they studied were significantly more likely to receive a high-cost loan than others.

... "Gym Crow"? Yet Another "innovation" at SECU?

 

Tuesday, December 5, 2023

Two-Martini Legal Advice: Asking The N.C Credit Union Division To Avoid Switches In Its X-Mas Stocking...

 

 

to:"Ray, Kristina W" <kristina.ray@nccud.nc.gov>
cc:"Badwan, Rana" <rbadwan@ncdoj.gov>,
Jamie Applequist <japlquist6@gmail.com>,
Amy Woody <AmyWoody@mountaincu.org>,
"to: Roger Montes" <Roger@latinoccu.org>,
Caleb Malcolm <calebamalcolm@gmail.com>,
dillondoc@gmail.com,
Fay Aand bill boyd <fayboyd@embarqmail.com>,
Lafayette Jones <lafayettegjones@gmail.com>

Dear Ms. Ray,

Happy Holidays! Took your advice and asked legal counsel for a review of our correspondence, over the last 6 months. As with most extended families, it's not too difficult to find a lawyer somewhere up the family tree willing to share an opinion - when, of course, paid an appropriate retainer. In this case, the hourly rate was two martinis, comfortable chair, roaring fireplace on a cold and rainy afternoon. 

Legal counsel said it was entirely appropriate for a consumer to ask a State regulator about her authority under N.C. State law. He pointed out the "Consumer Questions" section on the NCCUD website [here's the link] as a clear indicator of your responsibility and past willingness to respond to N.C. consumers; let alone the whole website heading: "Consumers" [here's the link], which includes "Consumer Information, Consumer Resources, Consumer Questions, File a Complaint". He also noted that on the website you were officially designated by NCCUD as the "go to person" [see link, at bottom] on any review of credit union rules and regulations. Lastly, he said it was unclear why you would refuse further clarification of the prior request, since responding to a consumer was clearly not an issue - as Administrator you have already crossed that bridge with our prior correspondence. 
 
The following alternatives were proposed:
  1. Politely re-request that the prior response to the two questions be clarified and state that a legal opinion is not being requested.
  2. Appeal the latest response to the Credit Union Commission.
  3. Ask a state-chartered credit union, as a courtesy, to file the 2 questions with the Administrator.
  4. Ask your N.C. State Representative (or any Representative) to file a request for answers to the 2 questions with the Administrator. Responses are generally mandatory.
  5. Ask your State Senator (or any Senator) to file a request for answers to the 2 questions with the Administrator. Responses are generally mandatory.
  6. Ask members from all across the State to also request that their Representative/Senator write the Administrator requesting an answer to the 2 questions. The more the merrier.
  7. Request through the Legislature that the Administrator be required to appear before any future hearing on H. 410  to answer these 2 questions and any others surrounding the role of NCCUD in the approval and monitoring of bylaw amendments.
  8. Encourage consumers/credit union members to attend the next Credit Union Commission Meeting (Spring 2024 Meeting coming up) to publicly comment on these 2 questions and other issues concerning the supervision of credit unions by the Administrator. Again, the more the merrier.
  9. File a formal complaint.
  10. All of the above.

 Thought all that was a fairly good two-martini investment. And, we can do any or all the above if you feel that is the way this must proceed.

Our strong preference however is #1. So our formal request is: Would you please clarify your prior (October 19, 2023) response to the 2 questions below. We are not requesting a legal opinion and understand you can not provide legal advice.

✔  Q: 1)  Is the N.C. Credit Union Division required by North Carolina law to monitor and enforce compliance by state-chartered credit unions with their bylaws?

Q: 2)  May a N.C. state-chartered credit union adopt rules, policies and procedures which effectively amend its bylaws without approval by the NCCUD
 
Thank you. We look forward to your prompt response .
 
Jean and Jim Blaine
December 5, 2023 
 
... sure know what I'd do... the right thing!