The Compliance 911 Show5 Huhti 2023

REMA’s: Their Use and Abuse by Regulators in the war against redlining

In this podcast, Len Suzio discusses his concerns about the threat posed to banks by the misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators in their fight against redlining. The DOJ's "Combatting redlining initiative" launched in October 2021 is one such example. Len highlights that the concept of REMA has no origin in law or regulation, making it vague and open to interpretation, which can lead to potential abuse.

Regulators often determine a bank's REMA based on factors like marketing campaigns, market plans, media usage, and self-produced promotional materials. If a bank's REMA is found to be larger than its Community Reinvestment Act (CRA) assessment area, the bank's lending outside its CRA-defined community could be subject to scrutiny for redlining.

Len shared his concern when federal examiners revealed that they use entire MSAs (Metropolitan Statistical Areas) or MDs (Metropolitan Divisions) as the basis for every bank's REMA, no matter the size of the bank. This approach makes almost every bank with an urban area nearby vulnerable to redlining accusations if they are not lending in the urban area.

The podcast concludes that this issue is alarming for banks, and they should be aware of the potential consequences of how their REMA is determined.

Brought to you by GeoDataVision and M&M Consulting

Tämä jakso on lisätty Podme-palveluun avoimen RSS-syötteen kautta eikä se ole Podmen omaa tuotantoa. Siksi jakso saattaa sisältää mainontaa.

Jaksot(100)

Community Development Benchmarks

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 ...

15 Heinä 12min

Unpacking FDIC Consumer Compliance 2026 Supervisory Highlights

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 satisfac...

25 Kesä 13min

CRA: The Importance of Assessment Areas

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 an...

17 Kesä 11min

AI Integration Into Compliance

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...

10 Kesä 13min

CRA: Other Ways in which banks help meet the needs of the community

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...

27 Touko 11min

Cyber Phishing

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 organizatio...

14 Touko 12min

CFPB NPR Section 1071 Compliance Dates

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 d...

4 Touko 11min

Compliance Risk Management in 2026

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...

10 Huhti 11min