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.
Hosts Len Suzio interviews Josh Silver of the National Community Reinvestment Coalition about his book Ending Redlining Through a Community-Centered Reform of the Community Reinvestment Act. They discuss the historical roots of redlining, how the CRA can promote fair lending, and the need to center community input in regulatory exams.
The episode covers practical topics for compliance professionals: disparate impact analysis, perfo...
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 ...
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 th...
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 ...
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 ...
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 Saving...
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 ...
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 ac...
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 a...
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, ...
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 ...
In this episode, Dean Stockford and Len Suzio discuss what compliance risk management should look like in 2026 as financial institutions face rising fraud, cyber threats, AI-related risks, third-party exposure, and an uncertain regulatory environment. Dean argues that compliance functions can no longer remain purely advisory and instead must evolve into active risk management and oversight roles, with stronger risk assessments, enh...
Len explains that the OCC issued a December 18, 2025 proposal to create a “Simplified Plan Process for Community Banks” to make the CRA strategic plan option easier, but he believes its real value extends beyond banks using strategic plans because it reveals how regulators think about “Satisfactory” and “Outstanding” performance under normal CRA standards. The proposal distinguishes between &ldqu...
This podcast episode discusses the alarming rise of cyber fraud in financial institutions, highlighting that global losses exceeded $1 trillion in 2025 and AI-powered attacks increased by 93%, including deepfake videos, voice cloning, and sophisticated phishing campaigns. The hosts explain that financial institutions are investing heavily in fraud prevention technologies such as AI fraud detection, predictive analytics, Open APIs w...
Len Suzio explains that although President Trump’s Executive Order 14281 aims to limit disparate impact liability, the legal status of disparate impact remains unsettled. The Supreme Court upheld disparate impact under the Fair Housing Act in Inclusive Communities but imposed strict limits requiring a clear causal link between a specific practice and disparities—limits often downplayed by regulators in re...
This episode provides a high-level recap of the major regulatory compliance themes covered in 2025. Dean highlights intense regulatory volatility, especially around CRA and Section 1071, including rule freezes, proposed repeals, litigation, delayed compliance dates, and the CFPB’s move toward an interim final rule for small-business lending data collection.
The discussion also revisits key fair lending, redlining, and data-a...
This episode focuses on common compliance problems under Regulation E, which governs electronic fund transfers and is designed to protect consumers using electronic channels such as ATMs, debit cards, online banking, and phone-initiated transfers. As electronic usage and fraud increase, regulators are finding frequent violations—especially around how financial institutions handle error resolution and consumer liability. A key...
This podcast highlights sweeping changes proposed for Section 1071 Rule that would dramatically shrink the volume of reportable small business lending and the number of institutions required to report in comparison to the lenders reporting under the CRA Rule. The most significant shift is redefining a “small business” from $5 million to $1 million in gross annual revenue, a change that would eliminate nearly half of cur...
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 majori...
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 du...
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