On a broadcast hosted by Dean Stockford, Len Suzio highlights the increase in adverse Community Reinvestment Act (CRA) ratings for banks in the first half of 2023. An article from Standard & Poor indicated that 12 banks received less than satisfactory performance ratings, a jump compared to 14 for the entirety of 2022. Len believes that this rise can be attributed to regulators enforcing stricter performance standards. Evidence for this includes the proposed new CRA Rule, which intends to set higher CRA performance standards. An analysis by bank regulators shows that the new rule would result in a significant increase in the CRA exam failure rate. Len emphasizes that the vagueness in the currently applied performance standards would allow regulators to implement the proposed calibrated standards without officially announcing them. Another notable factor impacting these ratings is the Fair Lending issue and the anti-redlining initiative. Len suggests that banks be aware of these changes and regularly self-evaluate their compliance with these 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
BSA Basics
REMA’s: Their Use and Abuse by Regulators in the war against redlining
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The new 2022 Census Tracts and their Impact on Banks.
UDAAP and CFPB Application of Unfairness`
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