A new insight into PPP loans and their potential impact on CRA performance

A new insight into PPP loans and their potential impact on CRA performance

A new insight into PPP loans reveals that it may be easier to substantiate them as qualified community development loans. One of the 4 different definitions of community development under CRA is the "economic development" definition. To be qualified for economic development a PPP loan had to meet the "size" test and the "purpose" test. However, banks were not required to collect the gross annual revenues of a PPP loan borrower and therefore did not have the data to substantiate whether the borrower met the size test. Noted CRA expert Len Suzio points out that all PPP loans had to meet the SBA size standards to be eligible to receive a PPP loan. That heretofore unrecognized fact means that every PPP loan is, ipso facto, qualified under the size test applied for economic development purposes.

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Avsnitt(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 Juli 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 Juni 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 Juni 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 Juni 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 Maj 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 Maj 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 Maj 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 Apr 11min

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