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 census tracts occurred by chance rather than discriminatory practices, using a 5% significance threshold, and that larger banks with more loan volume must perform closer to market averages to avoid being flagged (ranging from 5% for 100 applications to 9.5% for 10,000 applications when the market average is 10%). However, the analysis emphasizes that statistically significant results can be misleading due to "lurking" or "confounding" variables, particularly when regulators use unrealistic market definitions (UREMAs) that include areas where banks lack branches or competitive presence, or when peer comparisons inappropriately mix different institution types like banks and mortgage companies—situations that have resulted in the majority of actual peer banks failing the statistical test, demonstrating the data was fundamentally skewed and making the statistical significance analysis unreliable. Brought to you by GeoDataVision and M&M Consulting

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 lack of specific written regulations and varying interpretations from regulators. Key compliance issues include problems with contents coverage (especially when security documents contain blanket provisions securing all contents), timing delays in ordering determinations and notifications, failure to provide proper return receipt proof of notices, inadequate coverage calculations, insufficient ongoing monitoring, untimely force-placement, and improper vetting of private insurance policies. These violations can result in significant civil money penalties, making it essential for financial institutions to take flood insurance provisions seriously and ensure consistent compliance across all aspects of the program.Brought to you by GeoDataVision and M&M Consulting

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 lenders should take—retain strong fair lending programs, document business justifications, test for less discriminatory alternatives, and prepare for future reversals. Listeners get clear, practical guidance for compliance teams navigating uncertainty as enforcement shifts between federal agencies, state regulators, and private plaintiffs. Brought to you by GeoDataVision and M&M Consulting

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. The federal banking agencies are removing disparate impact references in their examination manuals and shifting toward intentional discrimination theories, while  use of the disparate impact theory by state authorities and private litigants remain risks. Banks and financial services companies should continue to review policies and procedures for potential disparate impact, conduct rigorous fair lending monitoring and testing, and prepare for potential future shifts in enforcement. Brought to you by GeoDataVision and M&M Consulting

Join top CRA experts Doctor Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act.   The NPR for repeal of the 2023 Rule What to be learned from the 2023 Rule Do the examiners in the field reflect "deregulation"? Simple ideas to improve the CRA regulations and make them more effective for banks What banks should do ASAP - and more   Brought to you by GeoDataVision and M&M Consulting

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, risk management, and customer service, they warn of the dangers of data bias and privacy concerns, stressing the need for strong governance and data quality controls. For AML/CTF, ongoing employee training, enhanced due diligence, and AI-driven transaction monitoring are crucial. The hosts recommend banks adopt clear, transparent, and unbiased AI policies with rigorous security, governance, and regulatory compliance frameworks to address these evolving risks and maintain customer trust. Brought to you by GeoDataVision and M&M Consulting

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 Reinvestment Act (CRA) requirements. They highlight how the new staggered compliance dates and partial-year reporting could create confusion, unnecessary costs, and data that’s not useful for analysis. The podcast encourages lenders to submit comments before the July 18, 2025 deadline, not just about compliance timing but also about issues like the expanded data requirements and demographic data isolation, and recommends all data collection start uniformly on January 1, 2028, to improve clarity and efficiency. Brought to you by GeoDataVision and M&M Consulting

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—which gave bankers a clearer way to measure and self-assess their CRA performance against both market and demographic standards. The conversation also notes that, while the new rule provided clarity on how to resolve conflicting performance results and prioritize ratings, its approach to consumer loans—making auto loans a key focus and sidelining other consumer loans—signals a shift in regulatory priorities. Ultimately, they agree that even if the 2023 rule is repealed, its measurement standards and lessons can help bankers better navigate the otherwise vague and inconsistent legacy CRA evaluation process.Brought to you by GeoDataVision and M&M Consulting

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 regulations, complex financial products, digital assets, and talent shortages, as well as the recent regulatory shifts like the rollback of the 2023 CRA rule and changing CFPB priorities. The hosts stress that proactive, values-driven compliance management helps institutions stay resilient, maintain stability, and navigate future regulatory swings, especially as concerns grow around data privacy, cybersecurity, and the integration of AI and automation. Brought to you by GeoDataVision and M&M Consulting      

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 undermines its intended purpose. Len urges bankers to actively support the rule's repeal, emphasizing the need for public education and constructive feedback to reshape regulatory policies effectively. Dean underscores the importance of understanding these flaws and advocating for regulatory changes that enhance rather than hinder the CRA's goals. Brought to you by GeoDataVision and M&M Consulting

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 the rise of different fraud types. They conclude with recommendations for financial institutions to enhance fraud controls through advanced technologies like AI, multi-factor authentication, and secure encryption protocols, emphasizing the importance of customer education and regulatory compliance. Brought to you by GeoDataVision and M&M Consulting

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 based on entire counties and remote retail lending areas, which could lead to misleading performance evaluations. Len urges the banking community to prepare for potential regulatory changes, provide feedback during the notice of proposed rulemaking, and advocate for more practical and effective rules. He also advises bankers to prepare testimony on these issues for when the proposed rule is published.Brought to you by GeoDataVision and M&M Consulting

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 elder financial exploitation. They also discuss the balance between intervention and autonomy, the evolving tactics of fraud, and the role of FIs in reporting suspicious activities. Recommendations for FIs include using AI-driven fraud detection, collaborating with various stakeholders, and providing tailored fraud prevention education for seniors.Brought to you by GeoDataVision and M&M Consulting

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, institutions must engage in comprehensive due diligence, assess their risk appetite, continuously monitor vendor relationships, and ensure that their contracts clearly outline responsibilities and safeguards. The conversation emphasizes that third-party risk management is a complex, ongoing process tailored to the unique needs and size of each institution, and that Boards of Directors must maintain oversight to ensure safe and sound operations. Brought to you by GeoDataVision and M&M Consulting

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 amendments, enforcement shifts, and litigation as probable paths for change, especially with the Trump Administration's focus on deregulation. Len critiques the 2023 CRA Rule for its complexity and rigidity in assessment areas, and he argues that Section 1071 exceeds congressional intent by mandating excessive data collection. Despite potential regulatory rollbacks, he warns that compliance remains critical since future administrations could reinstate stricter policies. He advises banks to maintain proactive compliance strategies to mitigate risks amid ongoing regulatory uncertainty.  Brought to you by GeoDataVision and M&M Consulting

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 dates approaching. While there is some uncertainty regarding whether these rules fall under the freeze, recent statements from administration officials suggest a delay is likely. Additionally, a congressional repeal effort for Section 1071 adds another layer of uncertainty. The hosts emphasize that, until official guidance is issued, banks should prepare as if the existing deadlines remain in effect, while staying informed and consulting legal counsel for clarity. Brought to you by GeoDataVision and M&M Consulting  

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 reporting requirements and global efforts to standardize compliance. AI-powered compliance tools, blockchain, and cybersecurity are also highlighted as both opportunities and risks, with new regulations likely addressing AI bias and data protection concerns. Additionally, banks must enhance third-party risk management and brace for increased scrutiny in consumer protection, digital banking, and financial inclusion efforts, particularly with changes to the Community Reinvestment Act (CRA) and Section 1071. The discussion underscores the importance of staying ahead of regulatory shifts to navigate an evolving financial landscape. Brought to you by GeoDataVision and M&M Consulting

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 about fairness and accuracy. A notable development evidenced in some recent examinations is a new peer definition for banks under examination, limiting comparisons to banks and credit unions with deposit-taking branches in the REMA. This adjustment, which excludes mortgage companies operating under different models, has shown more realistic results, often improving banks' minority penetration metrics. Banks are encouraged to incorporate this method into internal analyses, leveraging data from HMDA and regulatory websites, as it may mitigate potential DOJ referrals amidst intensified enforcement. Brought to you by GeoDataVision and M&M Consulting

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 marked "the first instance of a U.S. bank pleading guilty to conspiracy to commit money laundering" and describes a situation in which "TD Bank faced systemic compliance failures, including inadequate internal controls, deficient transaction monitoring, and neglect of suspicious activity reporting, leading to extensive violations of BSA/AML regulations". The podcast underscores the importance of well-resourced and up-to-date compliance programs, as TD Bank's deficiencies highlight the consequences of prioritizing other objectives over regulatory obligations. As stated in the DOJ press release, Deputy Attorney General Lisa Monaco said, "Every bank compliance official in America should be reviewing today's charges as a case study of what not to do. And every bank CEO and board member should be doing the same. Because if the business case for compliance wasn't clear before - it should be now". Brought to you by GeoDataVision and M&M Consulting

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, identifying covered lenders, and the implications of reporting requirements under Section 1071. As litigation continues to pose potential delays, our hosts emphasize the importance of getting a head start on compliance efforts. Listen as they unpack the various complexities and crossovers between CRA and Section 1071, helping you to strategize your compliance approach effectively while highlighting the possible pitfalls and the significance of maintaining proper data collection systems.Brought to you by GeoDataVision and M&M Consulting