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.
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Section 1071
Fair Lending Examiner Exceptions
Community Development under CRA
Fair Lending Appraisal Bias
Impending Changes to CRA & imminent publication of Dodd-Frank Section 1071 Rule
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REMA’s: Their Use and Abuse by Regulators in the war against redlining
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Pending CRA Proposed Rule
While Fair Lending remains a hot topic, do not forget about the technical provisions of ECOA and FHA.
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Fair Lending remains are of interest for regulators
The new 2022 Census Tracts and their Impact on Banks.
UDAAP and CFPB Application of Unfairness`
Flood Violations Continue to Surge
Urgent 🔥🔥The 2022 CRA NPR description🔥🔥
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