In a recent article in National Mortgage Professional entitled "Manufacturing Fair Lending”, former chief of the Housing and Civil Enforcement Section at the Department of Justice under Attorney General William Barr, Paul...more
6/17/2024
/ Banks ,
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
In this podcast episode, Dean and Len discuss the complexities surrounding redlining accusations faced by banks, particularly focusing on the implications of the 2020 Census data. Len explains that the increase in the number...more
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
The recent Supreme Court ruling that upheld the constitutionality of the Consumer Financial Protection Bureau’s funding resulted in the Bureau announcing the new effective dates for banks to begin collecting their CRA...more
5/31/2024
/ Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Reporting Requirements ,
Section 1071 ,
Small Business
Every banker should know by now that the Department of Justice announced an “Anti-Redlining” crusade in October 2021. In his October 2021, press release, Attorney General Merrick Garland, proclaimed that redlining is...more
This episode of the podcast, focusing on climate risk as an emerging regulatory compliance issue, features a dialogue between Len and Dean. They discuss how climate-related risks, especially in the financial sector, have...more
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
Podcast #71 of The Compliance 911 Show discusses how banks can estimate their performance under the new Community Reinvestment Act (CRA) rules. Len highlights bankers' concerns about the increased difficulty in passing the...more
The March 21, 2024, announcement that the prudential bank regulators have decided to postpone the scheduled April 1, “applicable” date for the Facility-based assessment areas, the new Public File section and the Public Notice...more
3/25/2024
/ Assessment ,
Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
Deadlines ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Postponement ,
Regulatory Requirements
With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers....more
3/20/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
HMDA ,
Lending ,
Loans ,
Low-Income Issues ,
Mortgages ,
Regulatory Requirements
The Retail Lending Test in the new CRA will measure bank performance against “market” benchmarks (lending activity reported by other lenders) and “community” benchmarks” (community demographics). Many bankers, although not...more
3/18/2024
/ Banks ,
Benchmarks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Low-Income Issues ,
Mortgage Loan Originators ,
Mortgages ,
OCC ,
Real Estate Transactions ,
Small Business Loans
Episode 70 of "Compliance 911, show" titled "2024 Regulatory Hot Topics," discusses the major regulatory challenges facing financial institutions in 2024. Hosts Len and Dean mark their 70th episode, reflecting on various...more
Episode 68 of the podcast discusses the investigation process for Electronic Funds Transfers (EFT) under the Electronic Fund Transfer Act. The hosts, Dean and Len, emphasize the importance of consumer protection in EFT and...more
There has been much understandable confusion about many aspects of the new CRA rule. But perhaps there’s been no greater confusion and anxiety than about the Assessment Areas. And this anxiety has become more acute the closer...more
Podcast #69, "The Coming Perfect Storm," features a discussion between Dean and Len Suzio about new regulatory challenges for the banking sector. Len highlights the implications of two key regulations: Section 1071 of the...more
In July 2023, the Office of Management & Budget published an update to “Core Based Statistical Areas, Metropolitan Divisions, and Combined Statistical Areas”. That document contains the latest definitions of Metropolitan...more
There has been much understandable handwringing about the new CRA and its complexity as well as the high CRA exam failure rate predicted by regulators based on the new assessment areas and the higher performance standards...more
2/26/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if...more
2/21/2024
/ Banking Examinations ,
Banks ,
Benchmarks ,
Community Development ,
Community Reinvestment Act ,
Consumer Financial Products ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loans ,
Mortgages
I have written a number of articles about the new CRA and the problems its requirements will impose on banks. But there are also problems posed by what the new Rule omits....more
2/7/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
HELOC ,
Lending ,
Loans ,
Mortgages ,
Real Estate Transactions
Our office has been inundated with inquiries about an aspect of the impact of the impending new CRA rule. As we have noted in previous articles there are mistakes and inconsistencies in the new CRA Rule, and some of these...more
As I write this article the Department of Justice is pursuing a record-breaking number of “redlining” cases against banks and mortgage lenders. The “Anti-redlining Initiative” was announced October 22, 2021, by Attorney...more
1/18/2024
/ 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
Climate Risk Assessments for banking purposes are in the early stages of development. No laws or regulations have been issued regarding the topic. Nonetheless, it is obvious that lawmakers and regulators are keenly intent on...more
1/3/2024
/ Analytics ,
Banks ,
Business Strategies ,
Climate Action Plan ,
Climate Change ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Risk Assessment ,
Risk Management
In episode 64 of the Compliance 911 podcast, hosts Len Suzio and Dean Stockford discuss the intricacies of Reg. CC, a regulation that deals with funds availability. Dean emphasizes the importance of understanding the...more
In the podcast, Len Suzio from GeoDataVision LLC and Dean Stockford of M&M Consulting delve into the topic of CRA (Community Reinvestment Act) Assessment Area delineation. Len emphasizes the critical importance of banks...more
The new CRA Rule has a number of surprises for banks and maybe a surprise or two for the regulators themselves. One of those surprises involves the transition rules in §__.51 as they pertain to the April 1, 2024, the...more