In this podcast episode, Len Suzio and Dean Stockford discuss the implications of the DOJ’s “Combatting Redlining Initiative" that was announced in 2021 and the ensuing increase in redlining referrals from bank regulators to the DOJ in 2022. Len believes this issue represents a significant regulatory compliance risk for banks, despite not being convinced of the DOJ's claim of widespread redlining practices today. Len's primary concern is the alleged misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators, which, in his view, has misleadingly expanded a bank’s Community Reinvestment Act (CRA) assessment area to include markets that are not practical for a bank to serve. This has been a factor in the record-breaking redlining referrals by bank regulators to the DOJ.
Len further explores commonalities among redlining cases, which mostly center on banks' inadequate procedures for identifying redlining risk exposure. He asserts that all lenders should promptly review their systems and procedures for identifying and monitoring potential redlining situations, ensuring they're not only adequate but also consistently implemented. The topic of REMAs versus CRA Assessment Areas is expanded, indicating that lenders should consider these as potentially different and evaluate their standing in relation to each. Len and Dean discuss key factors for REMA consideration, as described in the 2023 Fair Lending examination procedures, and the potential consequences if a bank's lending in REMA minority communities is statistically significantly low.
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A Very Serious and Growing CRA Assessment Area Problem
Enterprise Risk Management
CRA Tips and Tricks for Intermediate-Small Banks
Overview of Flood Insurance Requirements
CRA Mistakes
Fair Lending and Commercial Applications
Assessment Area delineation your most important CRA decision
Fair Lending in 2021
What Community Development really means under CRA
National Defense Act impacts on BSA/AML
The Pandemic and CRA
Compliance Management Systems and COVID
Major changes contained in the Federal Reserve Board's Advanced Notice of Proposed Rule-Making regarding the Community Reinvestment Act.
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