Hosts Len Suzio interviews Josh Silver of the National Community Reinvestment Coalition about his book Ending Redlining Through a Community-Centered Reform of the Community Reinvestment Act. They discuss the historical roots of redlining, how the CRA can promote fair lending, and the need to center community input in regulatory exams.

The episode covers practical topics for compliance professionals: disparate impact analysis, performance context, gentrification, assessment area challenges, and how documented community outreach and partnerships can improve CRA outcomes and reduce the risk of enforcement.

Get the book here: Ending Redlining by Josh Silver

Brought to you by GeoDataVision and M&M Consulting

Host Len Suzio welcomes Josh Silver of the National Community Reinvestment Coalition to discuss the regulators' Notice of Proposed Rulemaking on the Community Reinvestment Act. The episode focuses on the NPR's potential impacts, with a comment period ending October 13.

Josh highlights top concerns — higher asset thresholds reducing data reporting, streamlined exam types that could cut community development financing, and new nonprofit reporting burdens — while noting positives like improved community development data, attention to Native lands, and better CRA transparency on bank websites.

Get the book here: Ending Redlining by Josh Silver

Brought to you by GeoDataVision and M&M Consulting

In this episode of Compliance 911, Len Suzio and Dean Stockford examine the OCC and FDIC’s newly proposed revisions to the Community Reinvestment Act, focusing on how the rule could reshape bank classifications, reporting requirements, assessment areas, and performance evaluations. Len highlights the Federal Reserve’s absence from the proposal, predicts it may eventually join, and explains that raising the large-bank threshold to $10 billion could reduce the number of mandatory CRA reporters from more than 700 institutions to roughly 135, significantly weakening peer comparisons for small-business and small-farm lending. The discussion also addresses proposed restrictions on assessment area boundaries, whole-county requirements for large banks, the exclusion of loans made outside designated assessment areas, and changes to lending, service, complaint, and community development evaluations. Len argues that reduced reporting offers little meaningful relief because banks must still demonstrate CRA performance, and he encourages institutions to submit comments before the proposal is finalized.

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