The Compliance 911 Show

In this podcast, Len Suzio discusses his concerns about the threat posed to banks by the misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators in their fight against redlining. The DOJ's "Combatting redlining initiative" launched in October 2021 is one such example. Len highlights that the concept of REMA has no origin in law or regulation, making it vague and open to interpretation, which can lead to potential abuse.
Regulators often determine a bank's REMA based on factors like marketing campaigns, market plans, media usage, and self-produced promotional materials. If a bank's REMA is found to be larger than its Community Reinvestment Act (CRA) assessment area, the bank's lending outside its CRA-defined community could be subject to scrutiny for redlining.
Len shared his concern when federal examiners revealed that they use entire MSAs (Metropolitan Statistical Areas) or MDs (Metropolitan Divisions) as the basis for every bank's REMA, no matter the size of the bank. This approach makes almost every bank with an urban area nearby vulnerable to redlining accusations if they are not lending in the urban area.
The podcast concludes that this issue is alarming for banks, and they should be aware of the potential consequences of how their REMA is determined.
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In Episode 46 of the podcast series, Len and Dean discuss the 2023 regulatory hot topics facing financial institutions. They touch on multiple re-presentment fees, Dodd-Frank 1071 and its implications for small business data collection, and the forthcoming Cyber Security reporting requirements under the Critical Infrastructure Act of 2022. Climate risk is also identified as a significant area of focus for financial institutions, even for those below the $100 billion asset threshold. Lastly, they highlight fair lending, fraud, and potential changes to Reg. E as additional areas of interest for 2023. Throughout the episode, the hosts emphasize the importance of being proactive and staying informed about evolving regulations and guidance.Brought to you by GeoDataVision and M&M Consulting

This podcast deals with the big problems in the proposed CRA Rule. In it we discuss the 3 possible grounds for legal challenge if the Rule should be adopted as proposed. We also talk about the 3 most significant impacts of the proposed rule.
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While Fair Lending remains a hot topic, do not forget about the technical provisions of ECOA and FHA.
 
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Climate Risk Regulations are Coming. Learn what regulators are doing and how you can identify climate risk for 19 different natural hazards  for your bank.
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Overdraft programs and Junk fees, what you need to know featuring Dean Stockford and Len Suzio.
 
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Congresswoman Maxine Waters has submitted legislation that would amend the original Community Reinvestment Act in radical ways. Learn about her proposal for mandatory "Community Advisory Committees" and their role with bank management as well as other radical aspects of the proposed legislation in this broadcast.
 
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This podcast focuses on Compliance Management Systems. With everything coming at us from CRA, Fair Lending and UDAAP, it is imperative that financial institutions revisit CMS to ensure effective management.
 
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In this podcast, CRA expert Len Suzio explains how the CRA is being applied in the field with respect to Assessment Areas. The trend is for regulators to insist on expanded Assessment Areas which can dramatically increase the potential for failing a CRA exam due to inflated and unrealistic performance standards associated with Assessment Areas that a bank's branch network is not structured to serve. Don't miss this important topic. Be prepared for regulator pressure on your Assessment Area configuration!
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Fair Lending remains a hot area of interest for regulator’s.
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