The Compliance 911 Show

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. Brought to you by GeoDataVision and M&M Consulting  

This podcast discusses recent enforcement issues with Overdraft programs and UDAAP implications.   Brought to you by GeoDataVision and M&M Consulting

For many years bankers have wondered if there is a safe harbor under the various CRA tests but regulators would never comment on or disclose anything in response to questions about this matter. However, the 2020 NPR issued by the FDIC and the OCC and the 2020 ANPR proposed a concept the regulators called "comparators" that established a bright line for minimum performance that would rate as "satisfactory" performance for CRA examination purposes. Listen to CRA expert Len Suzio explain what the concept entails and how it would be calculated. Although not yet adopted, it gives insight into what Len describes as the "unofficial" performance standards.Brought to you by GeoDataVision and M&M Consulting

This podcast will give you a peek inside the emerging hot topic with regulators for 2022, climate risk.  Brought to you by GeoDataVision and M&M Consulting

PPP loans may be a thing of the past but they can still have a very big impact on your CRA performance in your next CRA exam. This podcast will cover the big impact PPP loans could have on your CRA performance rating and what you can still do to maximize that impact.   Brought to you by GeoDataVision and M&M Consulting

This podcast will address minimum due diligence and banking marijuana related businesses and customers. Brought to you by GeoDataVision and M&M Consulting

This podcast covers CRA practices that nationally recognized CRA expert Len Suzio recommends for every CRA officer and bank to implement. Brought to you by GeoDataVision and M&M Consulting

This podcast will cover high risk cyber risk areas headed into the holiday season and give you a snapshot of what hot risk topics we will see in 2022. Brought to you by GeoDataVision and M&M Consulting

This podcast will highlight the challenges and regulatory expectations with UDAAP. Brought to you by GeoDataVision and M&M Consulting

Learn about why small banks and especially Intermediate-Small Banks should voluntarily report their CRA activity. Brought to you by GeoDataVision and M&M Consulting