Is the Community Reinvestment Act Still Relevant to Mortgage Lending?

ABSTRACT The market share of conforming-size, home purchase mortgage originations has shifted from banking institutions to nonbank lenders. In 2017, nonbanks originated more than 1.8 million purchase mortgages (53% of the market), compared with 1.4 million by banks. Nonbanks originated 30% of purchase-money mortgages in 2000 and 24% in 2007. Does the declining role of banking institutions imply that the Community Reinvestment Act (CRA) is becoming less relevant to mortgage lending, since only they are subject to the requirements of the CRA? We address this question by exploring the changing composition of home purchase mortgage originations since 2000. We focus on the share of FHA and conforming-sized conventional loans to low- or moderate-income (LMI) households or to finance properties in LMI neighborhoods, and provide a more detailed examination of shifts in market composition than previous studies. Our analysis suggests that the CRA continues to be relevant to maintaining broad access to mortgage credit. We find that the overall share of loans to LMI borrowers has decreased compared with pre-2004, which we view as a reasonable benchmark period. However, this decrease has mostly been offset by an increased share to borrowers (broadly distributed by income) purchasing properties in LMI neighborhoods.