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
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its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule.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
President Trump signed Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy on April 23, 2025”. The EO proclaims a policy goal of eliminating “the use of disparate-impact liability in all contexts to the...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
Just when you thought the flurry of executive orders pertaining to “deregulation” might have slowed down, the President signed, on April 23, 2025, Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy.”...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
The podcast discusses recent regulatory developments following the issuance of an Executive Order by President Trump’s administration that froze regulatory actions. This freeze affects the proposal, issuance, and...more