CHLA Letter to CSBS: CRA for IMBs is counterproductive; more effective actions are available

In a letter to CSBS, the organization representing state regulators of non-banks, CHLA made a detailed case why CRA is not appropriate for IMBs and would likely discourage IMBs to lend in a state – and offered alternative more effective actions states could take to encourage IMBs to serve even more underserved borrowers