The Compliance 911 Show

"The New CRA" features a discussion between Dean Stockford and Len Suzio about the recent changes in the Community Reinvestment Act (CRA) regulations. Len has dedicated significant time to understanding the new CRA rule, which is a lengthy 1,494 pages, and has even published articles on the topic. He describes the new rule as an "unmitigated disaster for the banking industry," a conclusion drawn n...

In this podcast, Dean and Len discuss the September guidance from the CFPB concerning the Equal Credit Opportunity Act (ECOA), credit denials, and Artificial Intelligence (AI). The guidance emphasizes that lenders using AI for credit decisions must provide specific and accurate reasons for adverse actions. This includes updates to sample adverse action forms and checklists to reflect actual reason...

In Podcast #65 titled "The New CRA", Dean and Len discuss the recent changes introduced in the new Community Reinvestment Act (CRA) published just over a week ago. Len highlights three significant changes: the reclassification of bank categories based on their assets; the transformation in assessment areas which now include "facility-based assessment areas", "retail lending" assessment areas, and...

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 definitions within regulations as the same word or phrase might carry different meanings in different contexts. He goes on to explain that Reg. CC was implemented to enforce the provi...

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 updating their CRA assessment area maps, particularly in light of changes to census tracts that were officially adopted by the FFIEC on January 1, 2022. He is alarmed to find t...

Episode 62 of the podcast delves into the intricacies of Electronic Funds Transfers, primarily focusing on the basics of Regulation E (Reg. E) Error Resolution provisions and their stringent timelines for addressing claims. Dean Stockford and Len Suzio begin by discussing the impact of their previous podcasts, with Dean emphasizing the importance of understanding the Electronic Fund Transfer Act,...

On a broadcast hosted by Dean Stockford, Len Suzio highlights the increase in adverse Community Reinvestment Act (CRA) ratings for banks in the first half of 2023. An article from Standard & Poor indicated that 12 banks received less than satisfactory performance ratings, a jump compared to 14 for the entirety of 2022. Len believes that this rise can be attributed to regulators enforcing stric...

Len and Dean focus on Electronic Funds Transfers, particularly person-to-person (P2P) payment apps like Venmo, Apple Pay, and Zelle. Dean elaborates on the December 2021 update by the CFPB to the Reg. E FAQs. These guidelines stress that P2P payments, when they involve certain methods like a consumer’s debit card, are subject to the provisions of EFT-Regulation E. The Electronic Funds Transaction...

In this podcast episode, Dean and Len delve into pivotal questions concerning regulatory compliance in the banking sector. Len highlights the two primary questions every compliance and risk officer should ponder: whether their lending performance meets the expectations of examiners and if the performance is statistically significant.  The conversation comes against the backdrop of changes to the C...

In this podcast episode, Len and Dean discuss the challenges compliance officers face in keeping up with regulatory changes and guidance. They mention various regulations and topics that have been covered in previous episodes, such as CRA, Fair Lending, Redlining, BSA, AI, and more. They emphasize the importance of staying informed about regulatory changes and offer some techniques for compliance...

In this podcast episode, Len Suzio and Dean Stockford discuss the implications of the DOJ’s “Combatting Redlining Initiative" that was announced in 2021 and the ensuing increase in redlining referrals from bank regulators to the DOJ in 2022. Len believes this issue represents a significant regulatory compliance risk for banks, despite not being convinced of the DOJ's claim of widespread redlining...

In this podcast episode, Len Suzio and Dean Stockford discuss the unregulated use of Artificial Intelligence (AI) in the banking industry. Dean brings up how, amidst the focus on fair lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP), there have been increasing concerns about potential bias in AI systems. Specifically, red flags have been raised about scoring systems built into t...

In this podcast episode, Dean and Len discuss the implications of the new Section 1071 rule, which extends beyond the banking community. Len highlights that the number of reporters under Section 1071 is estimated to be four times greater than under the Community Reinvestment Act (CRA). They focus on the impact of Section 1071 on CRA reporting. Len mentions that the Office of the Comptroller of the...

In a podcast, hosts Len and Dean discussed the heightened focus on Enterprise Risk Management (ERM) within financial institutions. They highlighted the regulatory pressure spurred by issues like compliance, bank failures, Climate Risk, ESG factors, and political influences. Dean pointed out common gaps in ERM policies, such as lack of coverage for technology systems, strategic plans, and talent ma...

In this podcast episode, Dean and Len discuss the Section 1071 Rule, which is the hottest regulatory topic in the financial industry. Len provides an overview of the rule and its implications for lenders. Covered lenders, which include any financial institution that originates 100 or more covered loans for two consecutive years, will need to maintain a data collection system to report on their com...

This podcast episode discusses Fair Lending and focuses on examiner comments and specific examples of issues from regulators. The hosts, Len and Dean, discuss a scenario where a Compliance Officer or Fair Lending Officer in a community bank reviews loans for evidence of disparate treatment (Redlining). They find a series of portfolio loans where the borrowers received more favorable terms in the f...

In this episode of Podcast 51, hosts Dean and Len discuss the complexities of community development under the Community Reinvestment Act (CRA). They outline the four different definitions that qualify for community development credit: affordable housing, community services, economic development, and revitalization/stabilization. Len provides an in-depth explanation of each definition and shares ti...

In Episode 50 Len and Dean explore the issue of Fair Lending as it relates to appraisal bias. This emerging issue can lead to illegal discrimination within the appraisal process, impacting generational wealth building for minority consumers. Len and Dean discuss appraiser independence, the 2008 financial crisis, and how lenders can protect themselves against appraisal bias and potential liability...

In Podcast 49, Dean Stockford and Len Suzio discuss the impending changes to the Community Reinvestment Act (CRA) and the imminent publication of the Dodd-Frank Section 1071 Rule. The CRA Rule's publication date remains uncertain, while the Consumer Financial Protection Bureau (CFPB) is under court order to publish the Section 1071 Rule by March 31. Len notes that the 1071 Rule, which will have pr...

In this podcast episode, Len Suzio and Dean Stockford discuss the basics of the Bank Secrecy Act (BSA) and the importance of having a sound BSA program. They break down the extensive provisions of the BSA into two parts - the Basic Stuff (BS) and the Additional (A), which is pre and post 9/11. They also highlight the areas of high risk for non-compliance, including suspicious activity monitoring,...

In this podcast, Len Suzio discusses his concerns about the threat posed to banks by the misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators in their fight against redlining. The DOJ's "Combatting redlining initiative" launched in October 2021 is one such example. Len highlights that the concept of REMA has no origin in law or regulation, making it vague and open to inte...

In Episode 46 of the podcast series, Len and Dean discuss the 2023 regulatory hot topics facing financial institutions. They touch on multiple re-presentment fees, Dodd-Frank 1071 and its implications for small business data collection, and the forthcoming Cyber Security reporting requirements under the Critical Infrastructure Act of 2022. Climate risk is also identified as a significant area of f...

This podcast deals with the big problems in the proposed CRA Rule. In it we discuss the 3 possible grounds for legal challenge if the Rule should be adopted as proposed. We also talk about the 3 most significant impacts of the proposed rule. Brought to you by  GeoDataVision  and  M&M Consulting

While Fair Lending remains a hot topic, do not forget about the technical provisions of ECOA and FHA.   Brought to you by  GeoDataVision  and  M&M Consulting

Climate Risk Regulations are Coming. Learn what regulators are doing and how you can identify climate risk for 19 different natural hazards  for your bank. Brought to you by  GeoDataVision  and  M&M Consulting