The Compliance 911 Show
The Compliance 911 Show

The Compliance 911 Show

Dean Stockford - Len Suzio

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Welcome to Compliance 911, a no-nonsense, cut to the point, style show for today’s busy bank and credit union compliance professionals. With this series of bi-weekly shows our goal is to boil down some of today’s hottest regulatory compliance topics in quick and easy to digest 5-10 minute episodes so you can get the information you want and get on with your day. We’ll be discussing topics like CRA, HMDA, Fair Lending, Anti Money Laundering, and so much more. Don’t forget to subscribe and tell a friend about us! Follow M&M Consulting and GeoDataVision us on LinkedIn to get the latest updates.

Recent Episodes

Important CRA Lesson from OCC proposal for all Intermediate-Small and Large Banks
MAR 25, 2026
Important CRA Lesson from OCC proposal for all Intermediate-Small and Large Banks
Len explains that the OCC issued a December 18, 2025 proposal to create a “Simplified Plan Process for Community Banks” to make the CRA strategic plan option easier, but he believes its real value extends beyond banks using strategic plans because it reveals how regulators think about “Satisfactory” and “Outstanding” performance under normal CRA standards. The proposal distinguishes between “custom” bank-specific goals (which Len says offers little practical guidance) and “elective” goals, which are quantifiable targets drawn from approved plans and OCC supervisory experience. Len highlights that the most useful—and historically murky— CRA test is Community Development. The OCC's proposal provides explicit benchmarks for CD lending, investing, combined lending/investing, and CD services, using ratios tied to Tier 1 capital or total assets (including notably lower investment thresholds when a bank relies heavily on donations, acknowledging their significance). He notes the proposal also introduces measurable expectations for CD service hours per employee, while offering little new insight on traditional lending tests. Although the OCC states elective goals are not “safe harbors” and not formal benchmarks outside the simplified process, Len argues they align with what regulators historically expect and can help CRA officers set internal performance targets;  this is where you would provide a link to the 67 tests, performance standards and ratings. https://geodatavision.com/content/occ-proposed-elective-goals-for-cra-strategic-planning/Brought to you by GeoDataVision and M&M Consulting
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11 MIN