The Compliance 911 Show
The Compliance 911 Show is a bi-weekly podcast for bank and credit union compliance professionals. It covers regulatory topics like CRA, HMDA, Fair Lending, and Anti Money Laundering in quick 5-10 minute episodes. The show aims to provide concise, no-nonsense information to help busy professionals stay updated. Hosted by Dean Stockford and Len Suzio, it is associated with M&M Consulting and GeoDataVision.
Episodes
Ending Redlining: How the CRA Can Put Communities First
Hosts Len Suzio interviews Josh Silver of the National Community Reinvestment Coalition about his book Ending Redlining Through a Community-Centered Reform of the Community Reinvestment Act. They discuss the historical roots of redlining, how the CRA can promote fair lending, and the need to center community input in regulatory exams.
The episode covers practical topics for compliance professional
CRA Shake-Up: How the Regulators' NPR Could Bleed Community Funding
Host Len Suzio welcomes Josh Silver of the National Community Reinvestment Coalition to discuss the regulators' Notice of Proposed Rulemaking on the Community Reinvestment Act. The episode focuses on the NPR's potential impacts, with a comment period ending October 13.
Josh highlights top concerns — higher asset thresholds reducing data reporting, streamlined exam types that could cut community de
2026 CRA NPR
In this episode of Compliance 911, Len Suzio and Dean Stockford examine the OCC and FDIC’s newly proposed revisions to the Community Reinvestment Act, focusing on how the rule could reshape bank classifications, reporting requirements, assessment areas, and performance evaluations. Len highlights the Federal Reserve’s absence from the proposal, predicts it may eventually join, and explains that ra
Recent Regulatory Updates
In this episode of Compliance 911, Len Suzio and Dean Stockford review key banking and compliance developments from June 2026, including new OCC rules affirming federal banks’ authority over real estate escrow interest and fees, updated FDIC guidance on official signs and advertising, and CFPB changes to Regulation B that have created uncertainty around disparate impact and fair lending enforceme
Community Development Benchmarks
In this episode of Compliance 911, Dean Stockford and Len Suzio discuss the OCC’s proposed Community Development benchmarks for CRA performance, focusing on why community development has historically been difficult for banks to measure and plan. Len explains how the proposed benchmarks are organized by activity type—CD lending, qualified investments, services, and combined lending/investment activ
Unpacking FDIC Consumer Compliance 2026 Supervisory Highlights
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
CRA: The Importance of Assessment Areas
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
AI Integration Into Compliance
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
CRA: Other Ways in which banks help meet the needs of the community
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
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
CFPB NPR Section 1071 Compliance Dates
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
Compliance Risk Management in 2026
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,
Important CRA Lesson from OCC proposal for all Intermediate-Small and Large Banks
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
Cyber Fraud Risk
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
Disparate Impact
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
2025 Recap
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 l
Electronic Funds Transfers Issues
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
The New Section 1071
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
Statistical Significance
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
Flood remains compliance challenge
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
Disparate Impact Derailed? What EO 14-281 Means for Fair Lending
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
Executive Order 14281: The End of Fair Lending Law Enforcement Through Use of the Disparate Impact Legal Theory?
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
Wild Times for the Community Reinvestment Act
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
Top challenges with Compliance Management
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
CFPB Extends Section 1071 Compliance Dates
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
2023 CRA Rule Repeal: Lessons to be Learned
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
Importance of Compliance Management in times of transition
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
The fatal flaws in the 2023 CRA rule
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
Fraud, the silent epidemic
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
Predictions regarding the 2023 CRA Rule and Section 1071 and how to prepare for expected developments
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
Elder Financial Exploitation
In this podcast episode, Len and Dean discuss a recent Joint Statement from regulators on "Elder Financial Exploitation." They explore the challenges financial institutions (FIs) face in protecting seniors from fraud while respecting their independence and privacy rights. Dean highlights key points from the guidance, including policies for governance, employee training, transaction holds, and trus
Third-Party Risk The competitive world of banking struggles to keep up with technological advances, particularly in a regulatory environment.
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 these partnerships come with a range of risks. Key risk categories include operational, cybersecurity, regulatory, reputational, financial, legal, and concentration risks. To m
Changes in the Evolving approach to redlining
In this podcast, Dean and Len discuss potential regulatory changes in 2025, particularly concerning the Community Reinvestment Act (CRA) and Section 1071 of Dodd-Frank. Len outlines five ways regulations can change: congressional legislation, regulatory agency amendments, enforcement changes, litigation, and the Congressional Review Act. He predicts that legislative action is unlikely due to polit
The Regulatory Situation After the Trump Executive Orders Regulatory Freeze Pending Review
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 implementation of rules, pending review by new agency heads. The conversation focuses on the implications for banking regulations, particularly Section 1071 and the 2023 CRA rule, both of
Navigating 2025: Key Compliance Challenges and Regulatory Trends in Banking
In this episode of The Compliance 911 Show, Dean and Len discuss the key regulatory and compliance trends expected in 2025. While a Republican-controlled government may signal potential regulatory easing, changes will take time to materialize, making 2025 a pivotal and costly year for compliance. Key areas of focus include anti-money laundering (AML) and know-your-customer (KYC) regulations, with
Changes in the Evolving approach to redlining
Podcast 87 explores the evolving regulatory approach to redlining enforcement, focusing on shifts since the DOJ launched its “Combatting Redlining Initiative” in 2021. Historically, redlining was assessed based on intent and loan denials, transitioning in 2009 to statistical analyses using "Reasonably Expected Market Areas" (REMA). Recently, regulators have expanded REMAs to entire metropolitan ar
Regulatory environment after the historic election and what we learned from the recent TD Bank penalty.
The discussion highlights the potential for regulatory shifts, particularly around CRA and Dodd-Frank 1071, though changes may take 18-24 months. The conversation shifts to the unprecedented $3 billion penalty against TD Bank.
In a press release from the Department of Justice, Attorney General Merrick Garland said, "By making its services convenient for criminals, TD Bank became one."
The press
Navigating the New Compliance Landscape: CRA and Section 1071
Welcome to another insightful episode of the Compliance 911 Show! In this episode, hosts Dean Stockford and Len Suzio dive deep into the challenges and impacts of the simultaneous implementation of the new CRA 2023 rule and the Section 1071 rule set to unfold over the next few years.
Our discussion focuses on how compliance officers can prepare for these significant changes, including understandin
FDIC Advertising & Signage rule changes
In this podcast, Dean Stockford and Len Suzio discuss the recent FDIC Advertising and Signage rule changes, which took effect on April 1, 2024, and aim to modernize compliance requirements to align with digital banking practices. Dean highlights the importance of these updates, which include modernized signage rules for branches, digital platforms, and ATMs, disclosures distinguishing insured depo
Teaching about the New Community Reinvestment Act with Linda Ezuka
In this episode of the Compliance 911 Show, hosts Dean Stockford and Len Suzio are joined by special guest Linda Ezuka for the second part of their series on the Community Reinvestment Act (CRA). Linda, the founder of CRA Today and the CRA Hub, shares her extensive expertise on CRA compliance, community development finance, and the new CRA rules introduced in 2023.
The discussion delves into the c
Mastering the Community Reinvestment Act with Linda Ezuka
Welcome to the Compliance 911 Show, where hosts Dean Stockford and Len Suzio dive into the intricacies of the Community Reinvestment Act (CRA) with special guest Linda Ezuka. Linda, the founder of CRAtoday and the CRAhub, shares her extensive experience and insights on how to master CRA compliance, stay exam-ready, and leverage capital for community development.
In this episode, Linda discusses th
Red Warning on Redlining: Looking Ahead
In Episode 81 of the podcast series "Red Warning on Redlining," Len and Dean continue their discussion with fair lending expert Lori Sommerfield, a partner at Troutman Pepper. They explore the future of redlining enforcement by DOJ and federal agencies through 2024 and beyond. Lori explains the Combatting Redlining Initiative's impact to date and coordination among the federal agencies, as well as
Red Warning on Redlining: Looking Back
In Episode 80 of the podcast series on regulatory compliance, Len and Dean discuss the topic of redlining with Lori Sommerfield, a partner at Troutman Pepper, in a new two-part series “Red Warning on Redlining.” Lori, a seasoned fair lending attorney, explains the traditional and modern definitions of redlining, emphasizing how regulators now primarily use Home Mortgage Disclosure Act (HMDA) data
Redlining Isn’t What it Used To Be
In a recent podcast, Len and Dean discuss the June 10 article "Manufacturing Fair Lending" from National Mortgage Professional, which delves into the "Modern Theory of Redlining" introduced by bank regulators after AG Merrick Garland's 2021 Combatting Redlining Initiative was announced. The article includes insights from notable figures like Paul Hancock former chief of the Housing and Civil Enfo
Elder Abuse-Financial Exploitation and Fraud
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 exploitation. Financial institutions reported over $27 billion in elder exploitation between June 2022 and June 2023. The abuse is categorized into elder scams and theft, with scams
The Court Decides But it Ain’t Over Till It’s Over
In "Podcast 77: The Court Decides But it Ain’t Over Till It’s Over," Dean and Len discuss the recent Supreme Court ruling on the Consumer Financial Protection Bureau (CFPB)'s funding, which upheld its constitutionality, much to the disappointment of many bankers who hoped for its dissolution. Despite this decision, other legal challenges to CFPB's regulations remain unresolved. Specifically, the p
Flood Basics still causing pain for some
This podcast discusses flood regulations for institutions lending money on properties. While there are many federal laws, some key ones being the National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973, institutions must comply to avoid penalties. This includes checking if a property is in a flood hazard area, notifying the borrower and requiring flood insurance if neces
Redlining Complications Caused by Implementation of 2020 Census Tracts
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 of census tracts and changes in their minority status have created challenges for banks, especially since these changes were announced late into 2022. He highlights how these
Discrimination and Bias in Residential Lending
In this podcast episode, Dean and Len discuss the timely issue of appraisal discrimination and bias within the context of Fair Lending. Dean highlights the FFIEC's recent guidance on mitigating risks related to discriminatory practices in property valuations and ensuring credible appraisals. Appraisal bias, which can result in minorities receiving lower property valuations, affects credit access a
The Texas Court’s Preliminary Injunction Against the 2023 Rule
In Podcast 73, Dean and Len discuss a recent preliminary injunction issued by a Texas federal judge against the 2023 Community Reinvestment Act (CRA) rule. This injunction has halted the implementation of the new rule, pending legal proceedings. The court found substantial grounds suggesting the federal banking regulators may have exceeded their authority in expanding CRA evaluation markets and in
Climate Risk, the emerging risk
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 gained attention in recent years. New York State is highlighted for its proactive stance in providing guidance for financial institutions on managing these risks, including a sect
How to estimate how your performance will look under the new CRA
Podcast #71 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 CRA exam with the new rules, which predict a significant rise in failure rates. He emphasizes the importance of the Retail Lending Test, explaining that failing this test results in an overall unsatisfact
2024 Regulatory Hot Topics
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 topics covered over the series. They delve into significant regulatory changes including the Community Reinvestment Act (CRA) reforms and Dodd-Frank 1071 rules, highlighting their
Electronic Funds Transfers-The Investigation Process
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 remittance transfers, outlining the process for consumers to dispute unauthorized or incorrect transactions. They stress that financial institutions must promptly begin investig
The Coming Perfect Storm
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 Dodd-Frank Act and the new Community Reinvestment Act (CRA) rule. Section 1071 requires detailed reporting of small business lending data, including race and ethnicity of borrowe
The New CRA II - Retail Lending Test
"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
ECOA Credit Denial and the use of AI
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
The New CRA - I
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
Reg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.
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
The Importance of Assessment Areas
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
Electronic Funds Transfers-The Basics
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,
What’s behind the increase in CRA Exam failures?
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
Electronic Funds Transfers-what you need to know when using cash applications such as Venmo
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
Statistical Measurements of compliance
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
Keeping up with all the new regulations
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
Combatting Redlining Initiative
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
Artificial Intelligence (AI) and Banking
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
Unveiling the Implications: How Section 1071 Reshapes Community Reinvestment Act Reporting
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
Back to ERM Basic
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
Section 1071
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
Fair Lending Examiner Exceptions
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
Community Development under CRA
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
Fair Lending Appraisal Bias
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
Impending Changes to CRA & imminent publication of Dodd-Frank Section 1071 Rule
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
BSA Basics
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,
REMA’s: Their Use and Abuse by Regulators in the war against redlining
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
2023 Regulatory Hot Topics
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
Pending CRA Proposed Rule
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.
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
The coming Climate Risk Regulations
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
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