The Compliance 911 Show23 Apr 2024

The Texas Court’s Preliminary Injunction Against the 2023 Rule

In Podcast 73, Dean and Len discuss a recent preliminary injunction issued by a Texas federal judge against the 2023 Community Reinvestment Act (CRA) rule. This injunction has halted the implementation of the new rule, pending legal proceedings. The court found substantial grounds suggesting the federal banking regulators may have exceeded their authority in expanding CRA evaluation markets and including deposits and other retail banking products under the regulation. The court's decision highlighted four key reasons for this view: the inconsistent interpretation of "entire community" in the new rule, the questionable authority to regulate beyond credit activities, the application of the "Major Questions Doctrine," and a substantial likelihood of plaintiff’s success with irreparable harm due to compliance costs. Dean and Len predict a favorable outcome for the plaintiffs, with the case likely progressing to the Supreme Court, prolonging the legal process into 2025. They advise banks to comply with the current rule and suggest banks compute and target the proposed calibrated benchmarks for at least a satisfactory performance rating on the Lending Test. The episode ends with Dean and Len emphasizing the importance of staying informed and prepared as the situation develops. Brought to you by GeoDataVision and M&M Consulting

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Episoder(100)

CRA Shake-Up: How the Regulators' NPR Could Bleed Community Funding

Host Len Suzio welcomes Josh Silver of the National Community Reinvestment Coalition to discuss the regulators' Notice of Proposed Rulemaking on the Community Reinvestment Act. The episode focuses on ...

10 Sep 25min

2026 CRA NPR

In this episode of Compliance 911, Len Suzio and Dean Stockford examine the OCC and FDIC’s newly proposed revisions to the Community Reinvestment Act, focusing on how the rule could reshape bank class...

20 Aug 17min

Recent Regulatory Updates

In this episode of Compliance 911, Len Suzio and Dean Stockford review key banking and compliance developments from June 2026, including new OCC rules affirming federal banks’ authority over real esta...

6 Aug 17min

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 Jul 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 Jun 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 Jun 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 Jun 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 Mai 11min