As I write this email there are fewer than 30 days to go before the comment period ends on the proposed CRA Rule that, based on data in the NPR, would increase the CRA exam failure rate by more than 500%.
Make no mistake about it, if passed as proposed, the proposed Rule will have serious negative consequences for banks - and the numbers in the proposed rulemaking make that abundantly clear!
Nationally recognized CRA experts Ken Thomas who literally wrote the book on CRA and Len Suzio will be interviewed by Dean Stockford, President of M&M Consulting during an informal Internet meeting to be broadcast on Monday, July 18, at 3 pm. The interview will be brief because we want to give participating bankers the maximum opportunity to interact with Ken and Len and discuss their questions and concerns about the 2022 CRA NPR. We expect the session to last for 90 minutes.