Effective July 7, 2026, mortgage companies that extend at least 200 mortgage originations in NY state are subject to a new regulation that requires them to meet the credit needs of the communities they serve. One of the first...more
2/11/2026
/ Community Development ,
Community Reinvestment Act ,
Housing Market ,
Lenders ,
Low Income Housing ,
Low-Income Issues ,
Mortgage Lenders ,
Mortgage Servicers ,
Mortgages ,
New Regulations ,
New York ,
Real Estate Development ,
Regulatory Requirements ,
State and Local Government
Your 2025 compliance year in review — breaking down CRA, 1071 updates and what’s coming next for risk, regulation, and exams....more
During the Biden presidency the prudential bank regulators and the DOJ began to prosecute cases of alleged redlining much more aggressively than had been historical practice. A key concept in almost all cases was the idea of...more
2/2/2026
/ Banking Examinations ,
Banking Regulators ,
Community Banks ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Services Industry ,
Mortgages ,
Redlining ,
Regulatory Oversight ,
Regulatory Reform ,
Statistical Analysis
Even if you don't use the strategic plan option or are examined by FDIC or FRB you should read this - At first glance most bankers would think that the OCC’s proposed simplified CRA strategic plan process would not be of...more
1/28/2026
/ Banks ,
Community Banks ,
Community Development ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
FDIC ,
Federal Reserve ,
Investment ,
Investors ,
Low-Income Issues ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Prudential Standards ,
Real Estate Development ,
Regulatory Oversight ,
Regulatory Requirements
The Community Reinvestment Act mandates that a bank meets the credit needs of the communities which it serves as delineated by its CRA assessment areas. The regulation has a simple test to address that issue. It's called the...more
1/27/2026
/ Banking Sector ,
Banks ,
Community Banks ,
Community Reinvestment Act ,
Depository Institutions ,
Financial Institutions ,
Financial Regulatory Reform ,
HMDA ,
Lenders ,
Loans ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Small Business Loans
Does it do the job?
On December 17, 2025, the Office of the Comptroller of the Currency (OCC) published proposed new guidance that is intended to streamline the process for a CRA-covered financial institution to obtain...more
1/9/2026
/ Banking Sector ,
Borrowers ,
Comment Period ,
Community Banks ,
Community Development ,
Community Reinvestment Act ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
OCC ,
Proposed Guidance ,
Regulatory Oversight ,
Regulatory Requirements
One of the headline-leading compliance issues during 2025 has been the Trump Administration’s announcement in Executive Order 14281(“Restoring Equality of Opportunity and Meritocracy”) to “seek to eliminate the use of...more
12/23/2025
/ Banking Regulators ,
Compliance Management Systems ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Disparate Impact ,
Executive Orders ,
Mortgage Lenders ,
Redlining ,
Regulatory Reform ,
Risk Management ,
Trump Administration
This episode examines common Regulation E compliance failures—especially misapplying the 60-day liability rule and delaying provisional credit during error resolution—and emphasizes that financial institutions need clear...more
There’s a lot of things in the world of bureaucratic regulations that don’t appear to make sense and can be downright funny and frustrating at times. For example, when I was in the state senate in Connecticut the Department...more
12/15/2025
/ Banking Sector ,
Banks ,
Community Banks ,
Data Collection ,
Deregulation ,
FFIEC ,
Financial Institutions ,
Financial Services Industry ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
The CFPB’s Section 1071 Proposal: Big Reduction in Reporters, Loans and Data Points - Does Drastic Reduction in Reporters and Loans Undermine Purpose? The CFPB’s proposal to modify the Section 1071 Rule offers significant...more
Statistical significance, using a 5% probability threshold, is a key tool in redlining allegations under the disparate impact theory, measuring the likelihood that a bank's low performance in minority areas occurred by...more
About 83% of CRA “covered” lenders do not report lending under CRA -
On November 13, the Federal Bank Regulatory Agencies announced the availability of the 2024 CRA lending activity of 731 lenders who reported data on...more
A golden opportunity has been lost -
On November 7, the FDIC announced a change to the consumer compliance examination cycle....more
11/13/2025
/ Banking Sector ,
Banks ,
Community Reinvestment Act ,
Consumer Protection Laws ,
ECOA ,
Fair Housing Act (FHA) ,
FDIC ,
Financial Services Industry ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Truth in Lending Act (TILA)
Even before President Trump was sworn into office on January 20, 2025, the banking community and community activists were abuzz about the Trump Administration’s announced intentions to relax regulatory enforcement. ...more
In October 2021, the then Attorney General, Merrick Garland, announced the Combating Redlining Initiative (“CRI”) Shortly thereafter, federal banking regulators began a record-breaking number of referrals to the Department of...more
10/30/2025
/ Anti-Discrimination Policies ,
Banks ,
Discrimination ,
Disparate Impact ,
Enforcement Actions ,
Fair Lending ,
Financial Services Industry ,
Mortgage Lenders ,
Redlining ,
Regulatory Oversight ,
Statistical Analysis
The podcast highlights how financial institutions continue to struggle with flood insurance compliance due to unclear regulations and inconsistent interpretations, leading to common violations such as coverage errors,...more
If you are worried about “redlining” you’d better understand statistical significance -
The perennial question facing all banks is, “What volume of lending in Majority-Minority census tracts and mortgages extended to...more
10/21/2025
/ Banking Regulators ,
Banks ,
Bias ,
Community Reinvestment Act ,
Consumer Lenders ,
Discriminatory Lending Practices ,
Fair Lending ,
Financial Services Industry ,
Lenders ,
Minorities ,
Mortgage Lenders ,
Redlining
Dear Senators,
I have been a consultant regarding the Community Reinvestment Act since 1994 and have advised hundreds of banks and occasionally a community group about an institution’s CRA responsibilities. I am one of...more
9/29/2025
/ Affordable Housing ,
Banking Sector ,
Banks ,
Community Development ,
Community Reinvestment Act ,
Financial Services Industry ,
Lending ,
Mortgage Lenders ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process ,
Small Business
If they did here's one way to handle it -
Under the Biden Administration the prudential bank regulators and the Department of Justice initiated a program of aggressive enforcement against redlining by lenders of all types....more
9/16/2025
/ Banks ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Equal Access to Credit ,
Financial Services Industry ,
HMDA ,
Lenders ,
Mortgage Lenders ,
Redlining ,
Regulatory Oversight ,
Statistical Analysis
Dean Stockford and Len Suzio welcome Lori Sommerfield of Troutman Pepper Locke LLP to discuss President Trump’s Executive Order 14281, which limits federal use of the disparate impact theory in fair lending enforcement,...more
Regulatory Compliance has been an ever-evolving process for decades. But at least the changes have been mostly steady and slow. But during the last 15 years the pace of regulatory change has not only accelerated, but it’s...more
9/3/2025
/ Banks ,
Biden Administration ,
Community Reinvestment Act ,
Consumer Financial Products ,
Cooperative Compliance Regime ,
Department of Justice (DOJ) ,
Disparate Impact ,
ECOA ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
OCC ,
Regulatory Reform ,
Trump Administration
There’s a very big inconsistency in the Community Reinvestment Act. The current CRA rule was passed in 1995 and requires every FDIC insured bank to meet the credit needs of the communities they serve. All “covered” banks are...more
Join top CRA experts Dr. Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act....more
7/31/2025
/ Banking Sector ,
Banks ,
Community Reinvestment Act ,
Compliance ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Insured Depository Institutions ,
Lenders ,
Loans ,
Regulatory Oversight ,
Regulatory Requirements
The Trump Administration officially has announced it intends to emphasize “deregulation” with a focus of eliminating 10 regulations for every new regulation. Eliminating regulations is one thing, but enforcement is another...more
This episode explores key compliance challenges banks will face in 2025, highlighting regulatory expectations, technological advancements, and strategies for staying ahead.
...more