The New CRA II - Retail Lending Test

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 not from his personal opinion but from the regulators' own data. The new CRA rule significantly increases the failure rate of CRA exams for banks, estimated to be 10-12%, up from the long-term average of 1.2%. This increase is attributed to the new Retail Lending Test included in the rule.

The new rule introduces additional assessment areas for banks, leading to evaluations in markets far removed from their physical branches. This creates competitive disadvantages for banks in these remote areas, as they are evaluated against the same benchmarks as local lenders. The failure rates in these new assessment areas are alarmingly high, with estimates of 22.4% for Retail Lending Assessment Areas and 28.8% for Outside Retail Lending Areas.

Len highlights that the complexity and size of the new rule, along with the extensive data manipulations required for compliance, may be overwhelming for many. He cites quotes from regulators that explicitly state that the increased failure rate was a deliberate intent of the regulators to "raise the bar" for CRA performance evaluations.

Dean concludes the podcast by expressing that listeners will likely be apprehensive yet eager to learn more about the changes in the new CRA. Both hosts encourage listeners to send in suggestions for future podcast topics.

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