The Compliance 911 Show

This episode provides a high-level recap of the major regulatory compliance themes covered in 2025. Dean highlights intense regulatory volatility, especially around CRA and Section 1071, including rule freezes, proposed repeals, litigation, delayed compliance dates, and the CFPB’s move toward an interim final rule for small-business lending data collection.

The discussion also revisits key fair lending, redlining, and data-analysis topics, along with rising operational risks such as BSA/AML/KYC modernization, third-party risk management, and expanding concerns around AI, data governance, cybersecurity, and privacy. Consumer protection issues featured prominently, particularly Regulation E error-resolution failures, elder financial exploitation, and recurring flood compliance violations.

The takeaway for compliance and risk officers: conduct a CMS health check, document lessons learned from 2025, and proactively brief senior management and the board with a clear 2026 risk and compliance plan focused on these evolving priorities. Brought to you by GeoDataVision and M&M Consulting

This episode focuses on common compliance problems under Regulation E, which governs electronic fund transfers and is designed to protect consumers using electronic channels such as ATMs, debit cards, online banking, and phone-initiated transfers. As electronic usage and fraud increase, regulators are finding frequent violations—especially around how financial institutions handle error resolution and consumer liability. A key issue is the improper application of liability limits when consumers report unauthorized transactions, particularly misunderstanding the 60-day rule tied to periodic statements, which can expose consumers to unlimited liability for later transactions if they delay reporting. Another major concern is failures in the provisional credit process—institutions often delay investigations beyond allowed timeframes without issuing timely provisional credit (including interest), despite clear requirements to begin investigations promptly and credit the consumer if more time is needed. The takeaway is that financial institutions must have clear, accurate procedures and well-trained staff to ensure timely investigations, proper liability determinations, and full compliance with Regulation E’s consumer protections.

Brought to you by GeoDataVision and M&M Consulting

This podcast highlights sweeping changes proposed for Section 1071 Rule that would dramatically shrink the volume of reportable small business lending and the number of institutions required to report in comparison to the lenders reporting under the CRA Rule. The most significant shift is redefining a “small business” from $5 million to $1 million in gross annual revenue, a change that would eliminate nearly half of currently reported (compared to CRA reporters) small business loans, which is magnified even further when combined with the proposal to exclude renewals (unless the loan amount increases).

The Section 1071 Rule's reporting threshold for "covered" lenders would jump from 100 to 1,000 small business originations in each of the prior two calendar years. Under the current CRA Rule about 700 lenders are required to report. In comparison, under the proposed Section 1071 Rule only about 80 of those lenders have enough loan volume to be required to report under that Rule. In fact, among those potential Section 1071 lenders, the top10 would generate more than 91% of the reported small business lending activity under Section 1071. The Section 1071 proposal would also drop agricultural loans from being reported and eliminate dozens of discretionary data points, greatly reducing transparency and regulatory insight. With such far-reaching implications, the presenters urge stakeholders to actively comment before the December 15, 2025 deadline rather than remain passive. Brought to you by GeoDataVision and M&M Consulting