Combatting Redlining Initiative

Combatting Redlining Initiative

In this podcast episode, Len Suzio and Dean Stockford discuss the implications of the DOJ’s “Combatting Redlining Initiative" that was announced in 2021 and the ensuing increase in redlining referrals from bank regulators to the DOJ in 2022. Len believes this issue represents a significant regulatory compliance risk for banks, despite not being convinced of the DOJ's claim of widespread redlining practices today. Len's primary concern is the alleged misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators, which, in his view, has misleadingly expanded a bank’s Community Reinvestment Act (CRA) assessment area to include markets that are not practical for a bank to serve. This has been a factor in the record-breaking redlining referrals by bank regulators to the DOJ.

Len further explores commonalities among redlining cases, which mostly center on banks' inadequate procedures for identifying redlining risk exposure. He asserts that all lenders should promptly review their systems and procedures for identifying and monitoring potential redlining situations, ensuring they're not only adequate but also consistently implemented. The topic of REMAs versus CRA Assessment Areas is expanded, indicating that lenders should consider these as potentially different and evaluate their standing in relation to each. Len and Dean discuss key factors for REMA consideration, as described in the 2023 Fair Lending examination procedures, and the potential consequences if a bank's lending in REMA minority communities is statistically significantly low.

Brought to you by GeoDataVision and M&M Consulting

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Jaksot(100)

Community Development Benchmarks

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

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

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

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

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

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

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

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

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