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OCC Proposed Simplified CRA Strategic Plan Process for Community banks

Does it do the job? On December 17, 2025, the Office of the Comptroller of the Currency (OCC) published proposed new guidance that is intended to streamline the process for a CRA-covered financial institution to obtain approval of a CRA strategic plan. Will the proposed changes have a significant impact on banks choosing the strategic […]

The Misunderstood Disparate Impact Concept

One of the headline-leading compliance issues during 2025 has been the Trump Administration’s announcement in Executive Order 14281(“Restoring Equality of Opportunity and Meritocracy”) to “seek to eliminate the use of disparate impact liability in all contexts to the maximum degree possible.” The focus of media coverage has been the impact on legal theory. – and […]

When Regulatory Relief is not Regulatory Relief

There’s a lot of things in the world of bureaucratic regulations that don’t appear to make sense and can be downright funny and frustrating at times. For example, when I was in the state senate in Connecticut the Department of Information Technology was known as “DOIT”. I thought, “What a great name for the department […]

Overview of the CFPB’s Section 1071 Proposal

The CFPB’s Section 1071 Proposal: Big Reduction in Reporters, Loans and Data Points Does Drastic Reduction in Reporters and Loans Undermine Purpose? The CFPB’s proposal to modify the Section 1071 Rule offers significant reporting relief (and some complications) in several ways: (1) the change in the definition of “small business”, (2) change in treatment of […]

Free Small Business Lending Market Rank & Share Reports

2024 CRA Aggregate & Disclosure Data was released by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as regulatory compliance purposes. We are making available the statewide Small Business Loan Market Rank & Market Share Report for free (limit 3 states […]

Free Market Share Reports for Small Business

The 2024 CRA Aggregate & Disclosure Data was released by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as regulatory compliance purposes. We are making available the statewide Small Business Loan Market Rank & Market Share Report for free (limit 3 states per […]

FFIEC Announces Release of 2024 CRA Lending Data

About 83% of CRA “covered” lenders do not report lending under CRA On November 13, the Federal Bank Regulatory Agencies announced the availability of the 2024 CRA lending activity of 731 lenders who reported data on their small business and small farm lending, as well as their community development lending activity. This represents a small […]

FDIC Announces Big Change to Consumer Compliance Exam Frequency

A golden opportunity has been lost On November 7, the FDIC announced a change to the consumer compliance examination cycle. Consumer compliance issues pertain to topics including Truth in Lending, Real Estate Settlement Procedures, Flood Insurance, the Equal Credit Opportunity Act, The Fair Housing Act, the Home Mortgage Disclosure Act, to name a few of […]

Do CRA Performance Ratings Indicate a Change in Regulatory Enforcement?

Even before President Trump was sworn into office on January 20, 2025, the banking community and community activists were abuzz about the Trump Administration’s announced intentions to relax regulatory enforcement. One of the primary manifestations of the Administration’s approach is reflected in the announcement by bank regulators of their intention to rescind the 2023 Community […]

Regulatory Compliance: When Statistical Significance Fails

In October 2021, the then Attorney General, Merrick Garland, announced the Combating Redlining Initiative (“CRI”) Shortly thereafter, federal banking regulators began a record-breaking number of referrals to the Department of Justice for alleged “redlining.” A key factor in all those referrals, was the use of “statistical significance” to identify situations in which a lender’s mortgage […]

Understanding Statistical Significance Analysis for Regulatory Compliance

If you are worried about “redlining” you’d better understand statistical significance The perennial question facing all banks is, “What volume of lending in Majority-Minority census tracts and mortgages extended to minority home borrowers must we do to avoid redlining allegations by bank regulators?” The answer provided by regulators is found in their application of the […]

2024 HMDA Mortgage Market Rank & Share Reports

The FFIEC released the official 2024 HMDA Aggregate & Disclosure file in June. GeoDataVision uses that data to create special market rank and market share reports for markets everywhere in the USA. This data is invaluable for CRA and Fair Lending analysis and is the same data used by examiners when conducting compliance exams. GeoDataVision […]

An Open Letter to Democrat Senators Urging Withdrawal of Proposed 2023 CRA Rule Repeal

Dear Senators, I have been a consultant regarding the Community Reinvestment Act since 1994 and have advised hundreds of banks and occasionally a community group about an institution’s CRA responsibilities. I am one of the few people in the country who thoroughly read and understood the 2023 rule, and I developed a 5-hour webinar series […]

Did the prudential bank regulators and the DOJ use questionable Statistical Analysis?

If they did here's one way to handle it Under the Biden Administration the prudential bank regulators and the Department of Justice initiated a program of aggressive enforcement against redlining by lenders of all types. Announced by Attorney General Merrick Garland in October 2021, the “Combatting Redlining Initiative” marked the beginning of a series of […]

The Regulatory Compliance Ping Pong Game

Regulatory Compliance has been an ever-evolving process for decades. But at least the changes have been mostly steady and slow. But during the last 15 years the pace of regulatory change has not only accelerated, but it’s also become a ping pong game among the last 4 presidential administrations. From Obama to Trump, from Trump […]

The Community Reinvestment Act Big Secret

There’s a very big inconsistency in the Community Reinvestment Act. The current CRA rule was passed in 1995 and requires every FDIC insured bank to meet the credit needs of the communities they serve. All “covered” banks are subject to CRA performance evaluations every 3-5 years. But although all covered lenders are required to fulfill […]

Wild Times for the Community Reinvestment Act: Celebrating 100 Episodes with CRA Legend Dr. Ken Thomas

A milestone discussion on the past, present, and future of the Community Reinvestment Act A Historic Milestone Meets a Historic Expert For our landmark 100th episode of the Compliance 9-1-1 Show, hosts Dean Stockford of M&M Consulting and Len Susio of Geodata Vision knew they needed someone special. Enter Dr. Kenneth H. Thomas, Ph.D. - quite literally […]

Is Regulatory Enforcement Contradicting Trump’s “Deregulation” Executive Order?

The Trump Administration officially has announced it intends to emphasize “deregulation” with a focus of eliminating 10 regulations for every new regulation. Eliminating regulations is one thing, but enforcement is another matter. Roy Cohn, who advised Trump early in his business career, once said, “Don’t tell me what the law says, tell me who the […]

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