The Compliance 911 Show

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.

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