Welcome to another insightful episode of the Compliance 911 Show! In this episode, hosts Dean Stockford and Len Susio 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 understanding the phased rollout plan, identifying covered lenders, and the implications of reporting requirements under Section 1071.

As litigation continues to pose potential delays, our hosts emphasize the importance of getting a head start on compliance efforts. Listen as they unpack the various complexities and crossovers between CRA and Section 1071, helping you to strategize your compliance approach effectively while highlighting the possible pitfalls and the significance of maintaining proper data collection systems.

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Navigating the New Compliance Landscape: CRA and Section 1071

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 deposits from non-deposit products, and mandatory written policies for compliance. The rule also addresses misrepresentations about FDIC insurance by IDIs and non-bank entities, clarifying disclosure requirements to prevent consumer confusion. With a mandatory compliance date of May 1, 2025, Dean urges institutions to act promptly to ensure compliance.

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FDIC Advertising & Signage rule changes

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 complexities and challenges posed by the new CRA regulations, including the concerns expressed by bankers about adapting to these changes. Linda provides valuable insights into how financial institutions can prepare for the transition, balancing the legacy CRA rules with the new requirements.

Linda also highlights the potential opportunities offered by the new CRA, such as partnerships with minority depository institutions and community development financial institutions. The conversation explores how these collaborations can enhance service to disadvantaged communities and improve financial literacy.

Additionally, the episode touches on the introduction of calibrated benchmarks for assessing bank performance, and the importance of understanding community context when evaluating CRA activities.

Join us for this informative session as we explore the evolving landscape of the Community Reinvestment Act and learn how banks and community groups can work together to better serve their communities.

CRAtoday: cratoday.com [https://cratoday.com/]

CRAhub: cratoday.com/hub [https://cratoday.com/hub/]

Linda: linda@cratoday.com

 

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Teaching about the New 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 the most common questions from bankers, the importance of performance context, and the challenges of identifying community development loans. She also emphasizes the need for CRA professionals to engage with their communities to truly understand and meet local credit needs.

Join us for an enlightening conversation that will equip you with the knowledge to navigate the complexities of the CRA and drive impactful community development initiatives.

CRAtoday: cratoday.com [https://cratoday.com/]

CRAhub: cratoday.com/hub [https://cratoday.com/hub/]

 

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Mastering the Community Reinvestment Act with Linda Ezuka

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 advises financial institutions on best practices to monitor and manage redlining risks. Implications of the U.S. Supreme Court's recent Loper Bright decision for redlining cases is also discussed. The episode emphasizes preparation and fair lending compliance for financial institutions.

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Red Warning on Redlining: Looking Ahead

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 to identify potential redlining activity without other evidence to support such claims. She also discusses the DOJ's "Combatting Redlining Initiative," which is a “whole of government” approach leveraging federal agencies, U.S. attorneys, and state attorneys general to eradicate redlining practices. The episode highlights the challenges financial institutions face under aggressive enforcement and the importance of monitoring for redlining risks.

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Red Warning on Redlining: Looking Back

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 Enforcement at the DOJ  and Brian Montgomery, former deputy secretary of HUD highlighting concerns about the government's push for racial balance in loan originations. Len also mentions his follow-up article, "Redlining Isn’t What it Used to Be," which criticizes regulators' use of statistics to allege redlining. They discuss the complexity of redlining enforcement, the legal battles, and the importance of banks proactively assessing their risk of redlining accusations. Len advises banks to conduct internal risk assessments and seek expert legal and consulting help if unfairly accused, while emphasizing the need for industry unity in opposing regulatory overreach.

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Redlining Isn’t What it Used To Be

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 being more prevalent. The FBI's report for 2023 shows a significant increase in scams targeting individuals aged 60 and older, causing over $3.4 billion in losses. Dean recommends reviewing FinCEN and CFPB guidelines to combat elder financial exploitation and acknowledges the FBI's efforts in recovering some of the lost funds. Both agree on the seriousness of the issue and thank their listeners for tuning in.

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Elder Abuse-Financial Exploitation and Fraud

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 podcast delves into ongoing litigation concerning Section 1071, which involves the CFPB's new rules for small business lending data collection. The discussion covers the timeline for compliance, the complex issues around additional data points required by the CFPB, and the high costs of implementation. Len advises small business lenders to begin preparing their data collection systems and utilize the "free look period" to test these systems before mandatory reporting begins. The conversation highlights the ongoing legal battles and regulatory challenges facing the financial industry.

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The Court Decides But it Ain’t Over Till It’s Over

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 necessary, properly handling escrows and monitoring, and even force-placing insurance if the borrower lets it lapse. Common violations include weak internal controls, issues with contents coverage, mistakes in timing and notification, miscalculations of coverage amounts, and failing to properly monitor or force-place insurance.

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Flood Basics still causing pain for some

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.

The Compliance 911 Show