Welcome to Compliance 911, a no-nonsense, cut to the point, style show for today’s busy bank and credit union compliance professionals. With this series of bi-weekly shows our goal is to boil down some of today’s hottest regulatory compliance topics in quick and easy to digest 5-10 minute episodes so you can get the information you want and get on with your day. We’ll be discussing topics like CRA, HMDA, Fair Lending, Anti Money Laundering, and so much more. Don’t forget to subscribe and tel ...
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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 prima…
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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 H…
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Elder Abuse-Financial Exploitation and Fraud
10:40
10:40
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10:40
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 …
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The Court Decides But it Ain’t Over Till It’s Over
12:26
12:26
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12:26
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 …
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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 t…
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Redlining Complications Caused by Implementation of 2020 Census Tracts
12:10
12:10
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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 …
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Discrimination and Bias in Residential Lending
12:35
12:35
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12:35
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 …
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The Texas Court’s Preliminary Injunction Against the 2023 Rule
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12:26
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12:26
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 au…
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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 inst…
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How to estimate how your performance will look under the new CRA
14:14
14:14
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14:14
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 f…
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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) ref…
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Electronic Funds Transfers-The Investigation Process
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12:41
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12:41
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 f…
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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 len…
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"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 disast…
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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 ac…
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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 assessme…
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Reg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.
12:04
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12:04
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…
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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 FFI…
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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 o…
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What’s behind the increase in CRA Exam failures?
10:14
10:14
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10:14
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 c…
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Electronic Funds Transfers-what you need to know when using cash applications such as Venmo
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12:23
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12:23
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 E…
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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 conversati…
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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…
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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 con…
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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 h…
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Unveiling the Implications: How Section 1071 Reshapes Community Reinvestment Act Reporting
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14:31
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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 …
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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 …
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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 mainta…
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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 th…
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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-…
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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 themselv…
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Impending Changes to CRA & imminent publication of Dodd-Frank Section 1071 Rule
12:43
12:43
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12:43
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…
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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-comp…
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REMA’s: Their Use and Abuse by Regulators in the war against redlining
12:48
12:48
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12:48
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 l…
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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 …
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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 ConsultingBy Dean Stockford - Len Suzio
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While Fair Lending remains a hot topic, do not forget about the technical provisions of ECOA and FHA.
23:53
23:53
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23:53
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 ConsultingBy Dean Stockford - Len Suzio
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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 ConsultingBy Dean Stockford - Len Suzio
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Overdraft programs and Junk fees, what you need to know
9:15
9:15
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9:15
Overdraft programs and Junk fees, what you need to know featuring Dean Stockford and Len Suzio. Brought to you by GeoDataVision and M&M ConsultingBy Dean Stockford - Len Suzio
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Congresswoman Maxine Waters has submitted legislation that would amend the original Community Reinvestment Act in radical ways. Learn about her proposal for mandatory "Community Advisory Committees" and their role with bank management as well as other radical aspects of the proposed legislation in this broadcast. Brought to you by GeoDataVision and…
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This podcast focuses on Compliance Management Systems. With everything coming at us from CRA, Fair Lending and UDAAP, it is imperative that financial institutions revisit CMS to ensure effective management. Brought to you by GeoDataVision and M&M ConsultingBy Dean Stockford - Len Suzio
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How is the CRA Rule being enforced in the field?
17:27
17:27
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17:27
In this podcast, CRA expert Len Suzio explains how the CRA is being applied in the field with respect to Assessment Areas. The trend is for regulators to insist on expanded Assessment Areas which can dramatically increase the potential for failing a CRA exam due to inflated and unrealistic performance standards associated with Assessment Areas that…
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Fair Lending remains are of interest for regulators
17:45
17:45
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17:45
Fair Lending remains a hot area of interest for regulator’s. Brought to you by GeoDataVision and M&M ConsultingBy Dean Stockford - Len Suzio
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The new 2022 Census Tracts and their Impact on Banks.
13:12
13:12
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13:12
This podcast covers the implementation of the new 2020 Census tracts effective January 1, 2022. It covers the impact of the new tracts for CRA in terms of the Community Reinvestment Act and Fair Lending. The new tracts are effective retroactive to the beginning of 2022. Brought to you by GeoDataVision and M&M Consulting…
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UDAAP and CFPB Application of Unfairness`
19:32
19:32
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19:32
This podcast will discuss the CFPB’s new application of Unfairness under UDAAP. Brought to you by GeoDataVision and M&M ConsultingBy Dean Stockford - Len Suzio
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This podcast will highlight ongoing flood issues as violations continue to surge. Brought to you by GeoDataVision and M&M ConsultingBy Dean Stockford - Len Suzio
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This podcast addresses the most significant aspects of the 2022 CRA NPR, including the projected 500% increase in CRA Exam failure rates detailed in the NPR. In the podcast noted CRA expert Len Suzio discusses the "Double Jeopardy" for Intermediate banks and the "Double Whammy" for Large banks including the most radical changes in Assessment Area d…
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Understanding the Bank CRA Size Categories and the Transition Rules
17:16
17:16
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17:16
Many bankers are casual about understanding the different bank size categories in the application of the CRA regulations. But transitioning from one size category to another has profound implications that banks need to understand and prepare for. In this podcast CRA expert Len Suzio goes beyond explaining the different size categories. He explains …
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Peak inside Fair Lending regulatory enforcement for 2022
9:54
9:54
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This podcast will give you a peak inside the current regulatory arena. Brought to you by GeoDataVision and M&M ConsultingBy Dean Stockford - Len Suzio
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A new insight into PPP loans and their potential impact on CRA performance
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8:30
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A new insight into PPP loans reveals that it may be easier to substantiate them as qualified community development loans. One of the 4 different definitions of community development under CRA is the "economic development" definition. To be qualified for economic development a PPP loan had to meet the "size" test and the "purpose" test. However, ban…
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