The Compliance 911 Show

In this podcast, Len and Dean discuss the potential impact of regulatory changes under the Trump Administration, particularly focusing on the 2023 Community Reinvestment Act (CRA) rule and Section 1071 rule. Len highlights significant problems with the 2023 CRA rule, especially the rigid new assessment area rules that could create unrealistic performance standards for banks. The new rule introduces assessment areas for large banks based on entire counties and remote retail lending areas, which could lead to misleading performance evaluations. Len urges the banking community to prepare for potential regulatory changes, provide feedback during the notice of proposed rulemaking, and advocate for more practical and effective rules. He also advises bankers to prepare testimony on these issues for when the proposed rule is published.Brought to you by GeoDataVision and M&M Consulting

In this podcast episode, Len and Dean discuss a recent Joint Statement from regulators on "Elder Financial Exploitation." They explore the challenges financial institutions (FIs) face in protecting seniors from fraud while respecting their independence and privacy rights. Dean highlights key points from the guidance, including policies for governance, employee training, transaction holds, and trusted contacts, aimed at preventing elder financial exploitation. They also discuss the balance between intervention and autonomy, the evolving tactics of fraud, and the role of FIs in reporting suspicious activities. Recommendations for FIs include using AI-driven fraud detection, collaborating with various stakeholders, and providing tailored fraud prevention education for seniors.Brought to you by GeoDataVision and M&M Consulting

In this podcast, the hosts discuss the importance of managing third-party risk for financial institutions. They highlight how institutions rely on external providers for technological innovation and operational support, but these partnerships come with a range of risks. Key risk categories include operational, cybersecurity, regulatory, reputational, financial, legal, and concentration risks. To manage these effectively, institutions must engage in comprehensive due diligence, assess their risk appetite, continuously monitor vendor relationships, and ensure that their contracts clearly outline responsibilities and safeguards. The conversation emphasizes that third-party risk management is a complex, ongoing process tailored to the unique needs and size of each institution, and that Boards of Directors must maintain oversight to ensure safe and sound operations.
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In this podcast, Dean and Len discuss potential regulatory changes in 2025, particularly concerning the Community Reinvestment Act (CRA) and Section 1071 of Dodd-Frank. Len outlines five ways regulations can change: congressional legislation, regulatory agency amendments, enforcement changes, litigation, and the Congressional Review Act. He predicts that legislative action is unlikely due to political gridlock but sees regulatory amendments, enforcement shifts, and litigation as probable paths for change, especially with the Trump Administration's focus on deregulation. Len critiques the 2023 CRA Rule for its complexity and rigidity in assessment areas, and he argues that Section 1071 exceeds congressional intent by mandating excessive data collection. Despite potential regulatory rollbacks, he warns that compliance remains critical since future administrations could reinstate stricter policies. He advises banks to maintain proactive compliance strategies to mitigate risks amid ongoing regulatory uncertainty. 
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The podcast discusses recent regulatory developments following the issuance of an Executive Order by President Trump’s administration that froze regulatory actions. This freeze affects the proposal, issuance, and implementation of rules, pending review by new agency heads. The conversation focuses on the implications for banking regulations, particularly Section 1071 and the 2023 CRA rule, both of which have controversial effective dates approaching. While there is some uncertainty regarding whether these rules fall under the freeze, recent statements from administration officials suggest a delay is likely. Additionally, a congressional repeal effort for Section 1071 adds another layer of uncertainty. The hosts emphasize that, until official guidance is issued, banks should prepare as if the existing deadlines remain in effect, while staying informed and consulting legal counsel for clarity.
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In this episode of The Compliance 911 Show, Dean and Len discuss the key regulatory and compliance trends expected in 2025. While a Republican-controlled government may signal potential regulatory easing, changes will take time to materialize, making 2025 a pivotal and costly year for compliance. Key areas of focus include anti-money laundering (AML) and know-your-customer (KYC) regulations, with FinCEN pushing for stricter reporting requirements and global efforts to standardize compliance. AI-powered compliance tools, blockchain, and cybersecurity are also highlighted as both opportunities and risks, with new regulations likely addressing AI bias and data protection concerns. Additionally, banks must enhance third-party risk management and brace for increased scrutiny in consumer protection, digital banking, and financial inclusion efforts, particularly with changes to the Community Reinvestment Act (CRA) and Section 1071. The discussion underscores the importance of staying ahead of regulatory shifts to navigate an evolving financial landscape.
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Podcast 87 explores the evolving regulatory approach to redlining enforcement, focusing on shifts since the DOJ launched its “Combatting Redlining Initiative” in 2021. Historically, redlining was assessed based on intent and loan denials, transitioning in 2009 to statistical analyses using "Reasonably Expected Market Areas" (REMA). Recently, regulators have expanded REMAs to entire metropolitan areas or states, raising concerns about fairness and accuracy. A notable development evidenced in some recent examinations is a new peer definition for banks under examination, limiting comparisons to banks and credit unions with deposit-taking branches in the REMA. This adjustment, which excludes mortgage companies operating under different models, has shown more realistic results, often improving banks' minority penetration metrics. Banks are encouraged to incorporate this method into internal analyses, leveraging data from HMDA and regulatory websites, as it may mitigate potential DOJ referrals amidst intensified enforcement.
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The discussion highlights the potential for regulatory shifts, particularly around CRA and Dodd-Frank 1071, though changes may take 18-24 months. The conversation shifts to the unprecedented $3 billion penalty against TD Bank.
In a press release from the  Department of Justice, Attorney General Merrick Garland said, "By making its services convenient for criminals, TD Bank became one." 
The press release also said the TD Bank plea marked "the first instance of a U.S. bank pleading guilty to conspiracy to commit money laundering" and describes a situation in which "TD Bank faced systemic compliance failures, including inadequate internal controls, deficient transaction monitoring, and neglect of suspicious activity reporting, leading to extensive violations of BSA/AML regulations".
The podcast underscores the importance of well-resourced and up-to-date compliance programs, as TD Bank's deficiencies highlight the consequences of prioritizing other objectives over regulatory obligations. As stated in the DOJ press release, Deputy Attorney General Lisa Monaco said, "Every bank compliance official in America should be reviewing today's charges as a case study of what not to do. And every bank CEO and board member should be doing the same. Because if the business case for compliance wasn't clear before - it should be now".
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Welcome to another insightful episode of the Compliance 911 Show! In this episode, hosts Dean Stockford and Len Suzio dive deep into the challenges and impacts of the simultaneous implementation of the new CRA 2023 rule and the Section 1071 rule set to unfold over the next few years.
Our discussion focuses on how compliance officers can prepare for these significant changes, including understanding the phased rollout plan, identifying covered lenders, and the implications of reporting requirements under Section 1071.
As litigation continues to pose potential delays, our hosts emphasize the importance of getting a head start on compliance efforts. Listen as they unpack the various complexities and crossovers between CRA and Section 1071, helping you to strategize your compliance approach effectively while highlighting the possible pitfalls and the significance of maintaining proper data collection systems.Brought to you by GeoDataVision and M&M Consulting

In this podcast, Dean Stockford and Len Suzio discuss the recent FDIC Advertising and Signage rule changes, which took effect on April 1, 2024, and aim to modernize compliance requirements to align with digital banking practices. Dean highlights the importance of these updates, which include modernized signage rules for branches, digital platforms, and ATMs, disclosures distinguishing insured deposits from non-deposit products, and mandatory written policies for compliance. The rule also addresses misrepresentations about FDIC insurance by IDIs and non-bank entities, clarifying disclosure requirements to prevent consumer confusion. With a mandatory compliance date of May 1, 2025, Dean urges institutions to act promptly to ensure compliance.
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