In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed…
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/ Administrative Law, Business Organizations, Commercial Law & Contracts, Finance & Banking, Real Estate - Residential
In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule:
1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment areas…
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/ Administrative Law, Finance & Banking, Consumer Protection
Len & Dean examine how the 2023 CRA rule and Section 1071 could impose unrealistic standards on banks through rigid assessment areas, urging the industry to engage in the rulemaking process and prepare for regulatory changes…
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/ Finance & Banking
Len and Dean discuss recent regulatory guidance on elder financial exploitation, emphasizing the need for financial institutions to balance intervention and senior autonomy through effective policies, AI-driven fraud detection,…
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/ Criminal Law, Finance & Banking
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. In fact, some of those flaws are so bad that they left the Trump Administration with only 2 choices, significantly…
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/ Administrative Law, Business Organizations, Commercial Law & Contracts, Finance & Banking, Consumer Protection
Yesterday, as I was writing this article the news broke about the regulators deciding they intend to rescind the 2023 CRA rule. My first reaction was to toss this article in the “trash” folder. But upon further reflection I…
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/ Administrative Law, Business Organizations, Finance & Banking, Real Estate - Residential
Today, March 28, the regulators announced what many have been anticipating. The Agencies issued a press release indicating they intend to rescind the 2023 CRA rule…
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/ Administrative Law, Finance & Banking
When the new CRA rule was published in late 2023 it contained some very serious flaws that need to be corrected. Fixing the flawed CRA rule should be a high priority for the Trump Administration because the new rule is scheduled…
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/ Administrative Law, Consumer Protection, Finance & Banking
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The new…
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/ Commercial Law & Contracts, Finance & Banking
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…
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/ Administrative Law, Finance & Banking
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…
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/ Commercial Law & Contracts, Finance & Banking, Securities Law
No sooner had President elect Trump’s win been announced that speculation began about the implications for bank regulations. “Trump Administration may upend banking industry,” proclaimed a headline in USA Today, while Yahoo News…
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/ Finance & Banking
During the last 15 years there have been notable changes in regulatory enforcement of potential redlining situations. This article addresses those changes…
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/ Civil Rights, Consumer Protection, Finance & Banking
When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it looks…
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/ Administrative Law, Consumer Protection, Finance & Banking
Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule. But perhaps their frustration should be focused on the regulators who have…
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/ Consumer Protection, Finance & Banking, Real Estate - Residential
