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 development financing, and new nonprofit reporting burdens — while noting positives like improved community development data, attention to Native lands, and better CRA transparency on bank websites.

Get the book here: Ending Redlining by Josh Silver [https://www.endredline.com/]

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CRA Shake-Up: How the Regulators' NPR Could Bleed Community Funding

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 raising the large-bank threshold to $10 billion could reduce the number of mandatory CRA reporters from more than 700 institutions to roughly 135, significantly weakening peer comparisons for small-business and small-farm lending. The discussion also addresses proposed restrictions on assessment area boundaries, whole-county requirements for large banks, the exclusion of loans made outside designated assessment areas, and changes to lending, service, complaint, and community development evaluations. Len argues that reduced reporting offers little meaningful relief because banks must still demonstrate CRA performance, and he encourages institutions to submit comments before the proposal is finalized.

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2026 CRA NPR

 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 enforcement. They also discuss a joint FinCEN advisory identifying red flags tied to fraud involving unauthorized employment, CFPB guidance on considering immigration status in ability-to-repay decisions, and expanded use of Section 314(b) information sharing for fraud and cyber-related activity. The episode concludes with FHA’s decision to make certain appraisal field reviews optional and an overview of the proposed 21st Century ROAD to Housing Act, which could provide regulatory relief for community banks through higher examination thresholds, brokered deposit reforms, streamlined bank formation, and support programs for smaller and newly chartered institutions.


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Recent Regulatory Updates

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 activity—as well as by performance rating, bank size, and annual measures such as Tier 1 capital, assets, and volunteer service hours. The episode highlights how these benchmarks may give community banks a clearer framework for setting CRA goals and evaluating satisfactory or outstanding community development performance. Listeners can also download GeoDataVision’s special PDF recap containing all 67 proposed Community Development lending, investing, and service benchmarks from the GeoDataVision website.

https://geodatavision.com/content/occ-proposed-elective-goals-for-cra-strategic-planning/

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Community Development Benchmarks

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 Transfers, Flood, Truth in Savings, HMDA, and third-party oversight, emphasizing that disclosure accuracy, timely error resolution, operational discipline, and vendor management remain critical priorities for banks.

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Unpacking FDIC Consumer Compliance 2026 Supervisory Highlights

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 excluding low- or moderate-income tracts, banks still have flexibility to define the area they can reasonably be expected to serve. The discussion emphasizes that overly large assessment areas can set banks up for poor CRA performance, even when the area is technically compliant, because the bank may be compared against markets it cannot realistically serve. Len gives an example of a one-branch bank in Los Angeles County that improved its CRA position by narrowing its assessment area to nearby census tracts where it actually lent and served customers. The episode concludes that banks should regularly review their CRA assessment areas, especially after branch changes or acquisitions, using mapping tools and performance data to ensure their areas are compliant, realistic, and aligned with their actual community lending activity.

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CRA: The Importance of Assessment Areas

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 and detect suspicious activity more effectively; regulatory change management, where AI can scan updates and map them to internal policies and controls; and risk assessments/reporting, where AI can aggregate data to give management and boards clearer insights. However, the episode emphasizes that AI is not a plug-and-play replacement for compliance professionals. Banks must maintain strong governance, transparency, explainability, data controls, model validation, documentation, human oversight, and clear escalation paths. The key message is that AI should support compliance judgment—not replace it—and institutions should start with low-risk, high-pain use cases, clean and govern their data, collaborate across departments, and be ready to explain their AI tools to regulators.

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AI Integration Into Compliance

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 credit for contractors, multifamily and small rental property financing reflected in HMDA data, affordable housing units supported by those loans, auto loans that help low-income borrowers access employment, and small business expansion loans that create jobs. The key point is that these activities can help paint a fuller, more favorable picture of how a bank is meeting community credit needs, but to receive consideration, banks must properly geocode the loans, collect relevant data, and ensure the information is reliable.

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CRA: Other Ways in which banks help meet the needs of the community

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 powered by generative AI, which has driven a dramatic surge in highly convincing and personalized attacks. Real-world incidents, including major corporate breaches and multimillion-dollar fraud cases, demonstrate the severe financial and operational consequences. Given this evolving threat landscape, organizations must prioritize continuous employee training, strengthen email authentication and filtering systems, adopt AI-driven detection tools, and implement multi-factor authentication, all while tailoring their defenses to their specific risk profiles to effectively mitigate phishing risks.

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Cyber Phishing

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 the reporting threshold from 100 to 1,000 small business loans in each of the prior two years, narrowing the definition of a small business from $5 million to $1 million in gross annual revenue, and excluding certain products like merchant cash advances, agricultural loans, and transactions of $1,000 or less. He argues that the most significant impact would come not from fewer data fields, but from the much smaller pool of covered lenders and loans, while also warning that the revised definition could create confusion with CRA reporting standards and increase the risk of errors.

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CFPB NPR Section 1071 Compliance Dates

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 som

The Compliance 911 Show · Zencastr

The Compliance 911 Show

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.