Dean and Len highlight why strong, proactive compliance management is crucial for financial institutions facing regulatory change and emerging risks....more
Now that the Trump Administration has announced its intention to repeal the 2023 CRA rule many bankers are way too eager to move on and forget about the soon-to-be-repealed rule. It was unbelievably complex, confusing and...more
Banks play a pivotal role in the economic wellbeing of our nation and local communities. Banks do this by being “financial intermediaries” facilitating the flow of funds between savers and borrowers. This obligation is so...more
5/29/2025
/ Affordable Housing ,
Banking Sector ,
Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Disclosure Requirements ,
Fair Lending ,
HMDA ,
Lenders ,
Mortgages ,
Regulatory Requirements
President Trump signed Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy on April 23, 2025”. The EO proclaims a policy goal of eliminating “the use of disparate-impact liability in all contexts to the...more
In Podcast 95, Len and Dean argue that the 2023 CRA rule is flawed and confusing, urging its repeal and calling for reforms that truly support community development....more
Just when you thought the flurry of executive orders pertaining to “deregulation” might have slowed down, the President signed, on April 23, 2025, Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy.”...more
Len and Dean examine the rising threat of bank fraud, its financial toll, and how institutions can fight back with technology, education, and compliance....more
Dear Banker,
Many bankers are easily confused by the technical requirements for loans in "disaster areas'' to be potentially qualified for community development credit under CRA. This brief article explains how to avoid...more
In the previous articles of this 4-part series, I identified and explained three types of fatal flaws in the 2023 CRA rule and I presented 5 suggestions to improve the effectiveness of the legacy CRA rule. In this article I...more
4/29/2025
/ Banking Sector ,
Banks ,
Community Reinvestment Act ,
CRA ,
Disclosure Requirements ,
Financial Institutions ,
FinTech ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements
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...more
4/28/2025
/ Banks ,
Community Reinvestment Act ,
CRA ,
Financial Institutions ,
Loans ,
Mortgages ,
Multi-Family Housing ,
Notice of Proposed Rulemaking (NOPR) ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Small Business ,
Urban Planning & Development
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...more
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...more
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...more
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,...more
4/4/2025
/ Banks ,
Community Reinvestment Act ,
Credit Ratings ,
Credit Reports ,
Creditors ,
Financial Regulatory Reform ,
Lenders ,
Loans ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Retailers ,
Trump Administration
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...more
3/31/2025
/ Banking Sector ,
Community Reinvestment Act ,
Creditors ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
Mortgages ,
Proposed Rules ,
Regulatory Reform ,
Regulatory Requirements ,
Small Business
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....more
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...more
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...more
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...more
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...more
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...more
During the last 15 years there have been notable changes in regulatory enforcement of potential redlining situations. This article addresses those changes....more
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...more
10/24/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
OCC ,
Performance Ranking Systems
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...more
10/9/2024
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Loans ,
Mortgages ,
Multi-Family Development ,
Real Estate Transactions
Readers of this article may think I am referring to Orcas, sometimes known as “killer whales.” But what I am referring to is the new form of Assessment Area in the 2023 CRA Rule. However, the analogy/metaphor may be...more