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
This episode explores key compliance challenges banks will face in 2025, highlighting regulatory expectations, technological advancements, and strategies for staying ahead.
...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
Dean and Len highlight why strong, proactive compliance management is crucial for financial institutions facing regulatory change and emerging risks....more
Len and Dean examine the rising threat of bank fraud, its financial toll, and how institutions can fight back with technology, education, and compliance....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
Len and Dean discuss recent regulatory guidance on elder financial exploitation, emphasizing the need for financial institutions to balance intervention and senior autonomy through effective policies, AI-driven fraud...more
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
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
In this podcast, the hosts discuss the importance of managing third-party risk for financial institutions. They highlight how institutions rely on external providers for technological innovation and operational support, but...more
No sooner had President elect Trump’s win been announced that speculation began about the implications for bank regulations. “Trump Administration may upend banking industry,” proclaimed a headline in USA Today, while Yahoo...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
Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is called a “REMA” or...more
8/27/2024
/ Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Redlining ,
Regulatory Requirements
Many bankers hear the term “Statistical Significance” but don’t know what it means and how it is relevant to potential fair lending violations. Typically, when an examiner is evaluating if a bank is redlining, they will...more
Len and Dean discuss the alarming issue of elder abuse in their 78th and 79th podcasts. Dean expresses concern, especially since he has elderly parents, and highlights recent statistics from FinCEN and the FBI on elder...more
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