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—something previous rules lacked—which gave bankers a clearer way to measure and self-assess their CRA performance against both market and demographic standards. The conversation also notes that, while the new rule provided clarity on how to resolve conflicting performance results and prioritize ratings, its approach to consumer loans—making auto loans a key focus and sidelining other consumer loans—signals a shift in regulatory priorities. Ultimately, they agree that even if the 2023 rule is repealed, its measurement standards and lessons can help bankers better navigate the otherwise vague and inconsistent legacy CRA evaluation process.
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2023 CRA Rule Repeal: Lessons to be Learned

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 challenges such as evolving regulations, complex financial products, digital assets, and talent shortages, as well as the recent regulatory shifts like the rollback of the 2023 CRA rule and changing CFPB priorities. The hosts stress that proactive, values-driven compliance management helps institutions stay resilient, maintain stability, and navigate future regulatory swings, especially as concerns grow around data privacy, cybersecurity, and the integration of AI and automation.

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Importance of Compliance Management in times of transition

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, which he claims is incomprehensible and undermines its intended purpose. Len urges bankers to actively support the rule's repeal, emphasizing the need for public education and constructive feedback to reshape regulatory policies effectively. Dean underscores the importance of understanding these flaws and advocating for regulatory changes that enhance rather than hinder the CRA's goals.

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The fatal flaws in the 2023 CRA rule

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 statistics on consumer losses and the rise of different fraud types. They conclude with recommendations for financial institutions to enhance fraud controls through advanced technologies like AI, multi-factor authentication, and secure encryption protocols, emphasizing the importance of customer education and regulatory compliance.


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Fraud, the silent epidemic

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 introduces assessment areas for large banks based on entire counties and remote retail lending areas, which could lead to misleading performance evaluations. Len urges the banking community to prepare for potential regulatory changes, provide feedback during the notice of proposed rulemaking, and advocate for more practical and effective rules. He also advises bankers to prepare testimony on these issues for when the proposed rule is published.
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Predictions regarding the 2023 CRA Rule and Section 1071 and how to prepare for expected developments

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 trusted contacts, aimed at preventing elder financial exploitation. They also discuss the balance between intervention and autonomy, the evolving tactics of fraud, and the role of FIs in reporting suspicious activities. Recommendations for FIs include using AI-driven fraud detection, collaborating with various stakeholders, and providing tailored fraud prevention education for seniors.

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Elder Financial Exploitation

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 manage these effectively, institutions must engage in comprehensive due diligence, assess their risk appetite, continuously monitor vendor relationships, and ensure that their contracts clearly outline responsibilities and safeguards. The conversation emphasizes that third-party risk management is a complex, ongoing process tailored to the unique needs and size of each institution, and that Boards of Directors must maintain oversight to ensure safe and sound operations.

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Third-Party Risk The competitive world of banking struggles to keep up with technological advances, particularly in a regulatory environment.

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 political gridlock but sees regulatory amendments, enforcement shifts, and litigation as probable paths for change, especially with the Trump Administration's focus on deregulation. Len critiques the 2023 CRA Rule for its complexity and rigidity in assessment areas, and he argues that Section 1071 exceeds congressional intent by mandating excessive data collection. Despite potential regulatory rollbacks, he warns that compliance remains critical since future administrations could reinstate stricter policies. He advises banks to maintain proactive compliance strategies to mitigate risks amid ongoing regulatory uncertainty. 


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Changes in the Evolving approach to redlining

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 which have controversial effective dates approaching. While there is some uncertainty regarding whether these rules fall under the freeze, recent statements from administration officials suggest a delay is likely. Additionally, a congressional repeal effort for Section 1071 adds another layer of uncertainty. The hosts emphasize that, until official guidance is issued, banks should prepare as if the existing deadlines remain in effect, while staying informed and consulting legal counsel for clarity.


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The Regulatory Situation After the Trump Executive Orders Regulatory Freeze Pending Review

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 FinCEN pushing for stricter reporting requirements and global efforts to standardize compliance. AI-powered compliance tools, blockchain, and cybersecurity are also highlighted as both opportunities and risks, with new regulations likely addressing AI bias and data protection concerns. Additionally, banks must enhance third-party risk management and brace for increased scrutiny in consumer protection, digital banking, and financial inclusion efforts, particularly with changes to the Community Reinvestment Act (CRA) and Section 1071. The discussion underscores the importance of staying ahead of regulatory shifts to navigate an evolving financial landscape.

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Navigating 2025: Key Compliance Challenges and Regulatory Trends in Banking

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 tell a friend about us! Follow M&M Consulting and GeoDataVision us on LinkedIn to get the latest updates.

Tom Sullivan

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