In Podcast 73, Dean and Len discuss a recent preliminary injunction issued by a Texas federal judge against the 2023 Community Reinvestment Act (CRA) rule. This injunction has halted the implementation of the new rule, pending legal proceedings. The court found substantial grounds suggesting the federal banking regulators may have exceeded their authority in expanding CRA evaluation markets and including deposits and other retail banking products under the regulation. The court's decision highlighted four key reasons for this view: the inconsistent interpretation of "entire community" in the new rule, the questionable authority to regulate beyond credit activities, the application of the "Major Questions Doctrine," and a substantial likelihood of plaintiff’s success with irreparable harm due to compliance costs. Dean and Len predict a favorable outcome for the plaintiffs, with the case likely progressing to the Supreme Court, prolonging the legal process into 2025. They advise banks to comply with the current rule and suggest banks compute and target the proposed calibrated benchmarks for at least a satisfactory performance rating on the Lending Test. The episode ends with Dean and Len emphasizing the importance of staying informed and prepared as the situation develops.
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Climate Risk, the emerging risk
How to estimate how your performance will look under the new CRA
2024 Regulatory Hot Topics
Electronic Funds Transfers-The Investigation Process
The Coming Perfect Storm
The New CRA II - Retail Lending Test
ECOA Credit Denial and the use of AI
The New CRA - I
Reg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.
The Importance of Assessment Areas
Electronic Funds Transfers-The Basics
What’s behind the increase in CRA Exam failures?
Electronic Funds Transfers-what you need to know when using cash applications such as Venmo
Statistical Measurements of compliance
Keeping up with all the new regulations
Combatting Redlining Initiative
Artificial Intelligence (AI) and Banking
Unveiling the Implications: How Section 1071 Reshapes Community Reinvestment Act Reporting
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