Join top CRA experts Dr. Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act....more
7/31/2025
/ Banking Sector ,
Banks ,
Community Reinvestment Act ,
Compliance ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Insured Depository Institutions ,
Lenders ,
Loans ,
Regulatory Oversight ,
Regulatory Requirements
The Trump Administration officially has announced it intends to emphasize “deregulation” with a focus of eliminating 10 regulations for every new regulation. Eliminating regulations is one thing, but enforcement is another...more
Bank regulators have announced their intention to repeal the 2023 CRA Rule. But it would be a mistake to stop there. For more than a decade there’s been a clamoring to “modernize” the CRA regulations. If the Administration...more
Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public...more
6/19/2025
/ Banking Regulators ,
Banks ,
Community Reinvestment Act ,
Competition ,
Data Collection ,
Disclosure Requirements ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Government Agencies ,
Loans ,
Regulatory Oversight ,
Regulatory Requirements ,
Small Business ,
Small Business Loans
The podcast discusses how the 2023 CRA rule's numerical benchmarks remain valuable for bankers despite the rule's likely repeal....more
Now that the Trump Administration has announced its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule. It was unbelievably complex, confusing and...more
In Podcast 95, Len and Dean argue that the 2023 CRA rule is flawed and confusing, urging its repeal and calling for reforms that truly support community development....more
Dear Banker,
Many bankers are easily confused by the technical requirements for loans in "disaster areas'' to be potentially qualified for community development credit under CRA. This brief article explains how to avoid...more
In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I...more
4/29/2025
/ Banking Sector ,
Banks ,
Community Reinvestment Act ,
CRA ,
Disclosure Requirements ,
Financial Institutions ,
FinTech ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements
In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more
4/28/2025
/ Banks ,
Community Reinvestment Act ,
CRA ,
Financial Institutions ,
Loans ,
Mortgages ,
Multi-Family Housing ,
Notice of Proposed Rulemaking (NOPR) ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business ,
Urban Planning & Development
In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule:
1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment...more
Len & Dean examine how the 2023 CRA rule and Section 1071 could impose unrealistic standards on banks through rigid assessment areas, urging the industry to engage in the rulemaking process and prepare for regulatory changes...more
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices,...more
4/4/2025
/ Banks ,
Community Reinvestment Act ,
Credit Ratings ,
Credit Reports ,
Creditors ,
Financial Regulatory Reform ,
Lenders ,
Loans ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Retailers ,
Trump Administration
Yesterday, as I was writing this article the news broke about the regulators deciding they intend to rescind the 2023 CRA rule. My first reaction was to toss this article in the “trash” folder. But upon further reflection I...more
3/31/2025
/ Banking Sector ,
Community Reinvestment Act ,
Creditors ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
Mortgages ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Small Business
Today, March 28, the regulators announced what many have been anticipating. The Agencies issued a press release indicating they intend to rescind the 2023 CRA rule....more
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is...more
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The...more
When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it...more
10/24/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
OCC ,
Performance Ranking Systems
Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule. But perhaps their frustration should be focused on the regulators who have...more
10/9/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Loans ,
Mortgages ,
Multi-Family Development ,
Real Estate Transactions
Readers of this article may think I am referring to Orcas, sometimes known as “killer whales.” But what I am referring to is the new form of Assessment Area in the 2023 CRA Rule. However, the analogy/metaphor may be...more
I’ve written articles critical of the Section 1071 Rule and the CFPB’s implementation of the new rule. For example, the scheduled “applicable dates” for data recording and reporting make no sense at all. As currently...more
9/6/2024
/ Borrowers ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Section 1071 ,
Small Business Loans
As any bank professional regulatory compliance professional knows redlining is the hottest issue today and has been since Attorney General Merrick Garland announced the “Combatting Redlining Initiative” in October 2021. Since...more
7/25/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining ,
Risk Management
When the Supreme Court decided in favor of the plaintiff in Loper Bright Enterprises et al vs. Gina Raimondo it overruled its decision in Chevron v. Natural Resources Defense Council, the so-called “Chevron Decision” which...more
7/16/2024
/ Administrative Procedure Act ,
Banks ,
Chevron Deference ,
Chevron v NRDC ,
Community Reinvestment Act ,
Consumer Financial Products ,
Depository Institutions ,
Financial Services Industry ,
Government Agencies ,
Judicial Authority ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Statutory Interpretation
In emails in recent months we've warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ....more
6/13/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
Now that a Texas court has issued a temporary injunction delaying the April 1, 2024, scheduled implementation of the new CRA Rule should bankers relax and assume that the new rule’s effective date has been delayed for at...more