The Compliance 911 Show

In this episode of Compliance 911, Len Suzio and Dean Stockford unpack the FDIC’s 2026 Consumer Compliance Supervisory Highlights, noting that while 98% of FDIC-supervised institutions earned satisfactory or better ratings, weaknesses in compliance management systems continue to create risk. The discussion focuses on the most common violation areas, including Truth in Lending, Electronic Fund Tran...

The episode “CRA: The Importance of Assessment Areas” explains why a bank’s CRA assessment area is one of the most important decisions it makes, because it directly affects both performance results and the benchmarks examiners use during CRA reviews. Len explains that while CRA rules require banks to include whole census tracts, deposit-taking facility areas, surrounding lending areas, and avoid e...

The episode “AI Integration Into Compliance” explains how artificial intelligence is already becoming a practical tool for bank compliance teams as regulatory expectations rise, data volumes grow, and manual compliance processes become harder to sustain. Dean highlights three major areas where AI is creating value: transaction monitoring and AML, where machine learning can reduce false positives a...

This podcast explains that banks can strengthen their CRA exam performance by presenting additional lending activity that examiners may not otherwise consider, beyond the usual focus on small business, small farm, and community development loans. Len Suzio highlights several examples, including technically disqualified small business loans such as asset-based lines of credit, standby letters of cr...

Cyber phishing remains one of the most significant and rapidly growing cybersecurity threats, accounting for the vast majority of successful cyberattacks and impacting both individuals and organizations on a daily basis. As highlighted by Dean Stockford and Len Suzio, phishing schemes exploit human trust—rather than technical vulnerabilities—through increasingly sophisticated tactics, many now pow...

In this episode, Len Suzio and Dean Stockford discuss the CFPB’s November 2025 proposed rulemaking on Section 1071 and explain how it could dramatically scale back the current small business lending data-collection requirements. Len highlights the biggest proposed changes, including moving to a single compliance date of January 1, 2028, sharply reducing the number of required data points, raising...

In this episode, Dean Stockford and Len Suzio discuss what compliance risk management should look like in 2026 as financial institutions face rising fraud, cyber threats, AI-related risks, third-party exposure, and an uncertain regulatory environment. Dean argues that compliance functions can no longer remain purely advisory and instead must evolve into active risk management and oversight roles,...

Len explains that the OCC issued a December 18, 2025 proposal to create a “Simplified Plan Process for Community Banks” to make the CRA strategic plan option easier, but he believes its real value extends beyond banks using strategic plans because it reveals how regulators think about “Satisfactory” and “Outstanding” performance under normal CRA standards. The proposal distinguishes between “custo...

This podcast episode discusses the alarming rise of cyber fraud in financial institutions, highlighting that global losses exceeded $1 trillion in 2025 and AI-powered attacks increased by 93%, including deepfake videos, voice cloning, and sophisticated phishing campaigns. The hosts explain that financial institutions are investing heavily in fraud prevention technologies such as AI fraud detection...

Len Suzio explains that although President Trump’s Executive Order 14281 aims to limit disparate impact liability, the legal status of disparate impact remains unsettled. The Supreme Court upheld disparate impact under the Fair Housing Act in Inclusive Communities but imposed strict limits requiring a clear causal link between a specific practice and disparities—limits often downplayed by regulato...

This episode provides a high-level recap of the major regulatory compliance themes covered in 2025. Dean highlights intense regulatory volatility, especially around CRA and Section 1071, including rule freezes, proposed repeals, litigation, delayed compliance dates, and the CFPB’s move toward an interim final rule for small-business lending data collection. The discussion also revisits key fair le...

This episode focuses on common compliance problems under Regulation E, which governs electronic fund transfers and is designed to protect consumers using electronic channels such as ATMs, debit cards, online banking, and phone-initiated transfers. As electronic usage and fraud increase, regulators are finding frequent violations—especially around how financial institutions handle error resolution...

This podcast highlights sweeping changes proposed for Section 1071 Rule that would dramatically shrink the volume of reportable small business lending and the number of institutions required to report in comparison to the lenders reporting under the CRA Rule. The most significant shift is redefining a “small business” from $5 million to $1 million in gross annual revenue, a change that would elimi...

This podcast explains how statistical significance is used in redlining allegations based on disparate impact, despite potential deemphasis under the Trump Administration, as regulators may shift accusations from disparate impact to disparate treatment while still relying on statistical analysis. The hosts clarify that statistical significance measures the probability that a bank's below-average p...

This podcast discusses the persistent compliance challenges financial institutions face with flood insurance requirements. The hosts explain that while the statutory requirements seem straightforward—including determining if property is in a Special Flood Hazard Area (SFHA), providing proper notices, requiring adequate coverage, escrowing premiums, and force-placing insurance when necessary—many i...

Hosts Dean Stockford and Len Suzio welcome back attorney Lori Sommerfield, a partner at Troutman Pepper Locke LLP, to continue their two-part discussion of Executive Order 14-281 and its effort to curb disparate impact theory in fair lending enforcement. The episode covers the legal landscape post-EO, including the Supreme Court’s history, lingering federal versus state authority, private litigati...

Hosts Dean Stockford and Len Suzio welcome Lori Sommerfield, a partner at Troutman Pepper Locke LLP, to discuss and explain President Trump’s Executive Order 14281 (April 23, 2025), which directs federal agencies to limit use of the disparate impact theory in fair lending enforcement and to review existing guidance, pending matters, and consent orders that leverage that theory. The federal banking...

Join top CRA experts Doctor Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act.   The NPR for repeal of the 2023 Rule What to be learned from the 2023 Rule Do the examiners in the field reflect "deregulation"? Simple ideas to improve the CRA regulations and make them more effective for banks What banks should do ASAP - and more   Brought to you...

In this episode, Dean and Len focus on the top compliance management challenges financial institutions face in 2025, particularly in data privacy, cybersecurity, AI systems, and anti-money laundering/counter-terrorism financing (AML/CTF). They highlight how cyber threats—amplified by advances in AI—require robust encryption, advanced threat detection, and strict consent management. While AI and au...

In Episode 98, Dean and Len discuss the CFPB’s newly announced 2025 Section 1071 Interim Final Rule, which further delays the compliance dates for small business lending data collection and reporting by roughly one year for thousands of banks, credit unions, and commercial lenders. The hosts break down the complexities created by shifting rules, changes in definitions of “small business loan,” and...

In the podcast “2023 CRA Rule Repeal: Lessons to be Learned,” Dean Stockford and Len Suzio discuss the potential repeal of the complex 2023 Community Reinvestment Act (CRA) rule and argue that, despite its likely demise, valuable insights can still be drawn from it. Len highlights that the 2023 rule introduced a breakthrough by offering calibrated numerical benchmarks for CRA performance ratings—s...

In this episode, Dean and Len discuss the critical role of compliance management systems (CMS) within financial institutions, especially during periods of regulatory change and uncertainty. They emphasize that strong CMS is more than just box-checking—it is the foundation for harmonizing policies, monitoring risks, and ensuring ethical operations across departments. The conversation highlights cha...

In Podcast 95, Len and Dean delve into the critical flaws of the 2023 Community Reinvestment Act (CRA) rule, emphasizing its detrimental impact on banks and communities. Len highlights the rule's exclusion of crucial loan types like multifamily mortgages and open-end mortgages, arguing they are vital for community development. He criticizes the rule's overly complex performance rating system, whic...

In Episode 94 of their podcast series, Len and Dean discuss the pervasive issue of bank fraud, highlighting its various forms and staggering financial impacts. They cover topics such as credit card fraud, phishing, synthetic identities, and insider threats, citing significant increases in fraud incidents and financial losses globally. Dean provides insights from recent reports, including specific...

In this podcast, Len and Dean discuss the potential impact of regulatory changes under the Trump Administration, particularly focusing on the 2023 Community Reinvestment Act (CRA) rule and Section 1071 rule. Len highlights significant problems with the 2023 CRA rule, especially the rigid new assessment area rules that could create unrealistic performance standards for banks. The new rule introduce...