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.
This podcast explains how statistical significance is used in redlining allegations based on disparate impact, despite potential deemphasis under the Trump Administration, as regulators may shift accusations from disparate impact to disparate treatment while still relying on statistical analysis. The hosts clarify that statistical significance measures the probability that a bank's below-average performance in majority-minority cen...
This podcast discusses the persistent compliance challenges financial institutions face with flood insurance requirements. The hosts explain that while the statutory requirements seem straightforward—including determining if property is in a Special Flood Hazard Area (SFHA), providing proper notices, requiring adequate coverage, escrowing premiums, and force-placing insurance when necessary—many institutions struggle due to the lac...
Hosts Dean Stockford and Len Suzio welcome back attorney Lori Sommerfield, a partner at Troutman Pepper Locke LLP, to continue their two-part discussion of Executive Order 14-281 and its effort to curb disparate impact theory in fair lending enforcement.
The episode covers the legal landscape post-EO, including the Supreme Court’s history, lingering federal versus state authority, private litigation risks, and practical steps lende...
Hosts Dean Stockford and Len Suzio welcome Lori Sommerfield, a partner at Troutman Pepper Locke LLP, to discuss and explain President Trump’s Executive Order 14281 (April 23, 2025), which directs federal agencies to limit use of the disparate impact theory in fair lending enforcement and to review existing guidance, pending matters, and consent orders that leverage that theory.
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In this episode, Dean and Len focus on the top compliance management challenges financial institutions face in 2025, particularly in data privacy, cybersecurity, AI systems, and anti-money laundering/counter-terrorism financing (AML/CTF). They highlight how cyber threats—amplified by advances in AI—require robust encryption, advanced threat detection, and strict consent management. While AI and automation can streamline compliance,...
In Episode 98, Dean and Len discuss the CFPB’s newly announced 2025 Section 1071 Interim Final Rule, which further delays the compliance dates for small business lending data collection and reporting by roughly one year for thousands of banks, credit unions, and commercial lenders. The hosts break down the complexities created by shifting rules, changes in definitions of “small business loan,” and the overlap with Community Reinves...
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—whic...
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 regulation...
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...
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 t...
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 ...
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 e...
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, institutio...
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 a...
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...
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 reporti...
Podcast 87 explores the evolving regulatory approach to redlining enforcement, focusing on shifts since the DOJ launched its “Combatting Redlining Initiative” in 2021. Historically, redlining was assessed based on intent and loan denials, transitioning in 2009 to statistical analyses using "Reasonably Expected Market Areas" (REMA). Recently, regulators have expanded REMAs to entire metropolitan areas or states, raising concerns abo...
The discussion highlights the potential for regulatory shifts, particularly around CRA and Dodd-Frank 1071, though changes may take 18-24 months. The conversation shifts to the unprecedented $3 billion penalty against TD Bank.
In a press release from the Department of Justice, Attorney General Merrick Garland said, "By making its services convenient for criminals, TD Bank became one."
The press release also said the TD Bank plea ...
Welcome to another insightful episode of the Compliance 911 Show! In this episode, hosts Dean Stockford and Len Suzio 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, identify...
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