The Compliance 911 Show

Hosts Len Suzio interviews Josh Silver of the National Community Reinvestment Coalition about his book Ending Redlining Through a Community-Centered Reform of the Community Reinvestment Act. They discuss the historical roots of redlining, how the CRA can promote fair lending, and the need to center community input in regulatory exams. The episode covers practical topics for compliance professionals: disparate impact analysis, performance context, gentrification, assessment area challenges, and how documented community outreach and partnerships can improve CRA outcomes and reduce the risk of enforcement. Get the book here: Ending Redlining by Josh Silver Brought to you by GeoDataVision and M&M Consulting

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 the NPR's potential impacts, with a comment period ending October 13. Josh highlights top concerns — higher asset thresholds reducing data reporting, streamlined exam types that could cut community development financing, and new nonprofit reporting burdens — while noting positives like improved community development data, attention to Native lands, and better CRA transparency on bank websites. Get the book here: Ending Redlining by Josh Silver Brought to you by GeoDataVision and M&M Consulting

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 classifications, reporting requirements, assessment areas, and performance evaluations. Len highlights the Federal Reserve’s absence from the proposal, predicts it may eventually join, and explains that raising the large-bank threshold to $10 billion could reduce the number of mandatory CRA reporters from more than 700 institutions to roughly 135, significantly weakening peer comparisons for small-business and small-farm lending. The discussion also addresses proposed restrictions on assessment area boundaries, whole-county requirements for large banks, the exclusion of loans made outside designated assessment areas, and changes to lending, service, complaint, and community development evaluations. Len argues that reduced reporting offers little meaningful relief because banks must still demonstrate CRA performance, and he encourages institutions to submit comments before the proposal is finalized. Brought to you by GeoDataVision and M&M Consulting

 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 estate escrow interest and fees, updated FDIC guidance on official signs and advertising, and CFPB changes to Regulation B that have created uncertainty around disparate impact and fair lending enforcement. They also discuss a joint FinCEN advisory identifying red flags tied to fraud involving unauthorized employment, CFPB guidance on considering immigration status in ability-to-repay decisions, and expanded use of Section 314(b) information sharing for fraud and cyber-related activity. The episode concludes with FHA’s decision to make certain appraisal field reviews optional and an overview of the proposed 21st Century ROAD to Housing Act, which could provide regulatory relief for community banks through higher examination thresholds, brokered deposit reforms, streamlined bank formation, and support programs for smaller and newly chartered institutions. Brought to you by GeoDataVision and M&M Consulting

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 been difficult for banks to measure and plan. Len explains how the proposed benchmarks are organized by activity type—CD lending, qualified investments, services, and combined lending/investment activity—as well as by performance rating, bank size, and annual measures such as Tier 1 capital, assets, and volunteer service hours. The episode highlights how these benchmarks may give community banks a clearer framework for setting CRA goals and evaluating satisfactory or outstanding community development performance. Listeners can also download GeoDataVision’s special PDF recap containing all 67 proposed Community Development lending, investing, and service benchmarks from the GeoDataVision website. https://geodatavision.com/content/occ-proposed-elective-goals-for-cra-strategic-planning/ Brought to you by GeoDataVision and M&M Consulting