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    Unlocking the Code for a Successful CRA Examination
    (Published March/April 2016) In this ABA Bank Compliance article, Stephen Cross unlocks the code for a successful CRA examination, which includes knowing the end game, showing the relevant accomplishments of the bank, and placing a clear emphasis on performance, documentation and metrics.
    Know the End Game: Strategies for Creating a Forward-Looking CRA Plan
    (Published November 2015) Stephen Cross a Senior Director with Wolters Kluwer identifies a trend where federal banking regulators are increasingly requiring banks to prepare a CRA Plan as a condition of an approval.
    New BISG Proxy Methodology – What is it and why should you care?
    (Published January 8, 2015) The new BISG proxy methodology combines geography- and surname-based information into a single proxy probability for race and ethnicity. Learn why you should care and what tools there are to help you collect this data. What you don’t know could hurt you.
    Strengthening Risk Compliance Along Three Lines of Defense
    (Published January 2015) The changing regulatory landscape has introduced increased focus and heightened expectations for financial institutions around risk management and compliance risk management. Building a strong compliance culture and program starts with strategic planning built with the input from frontline units (the first line of defense), compliance units (the second line) and audit (the third line). This article, co-authored by Stephen Cross and Thomas Grundy, provides an overview of the three lines of defense and the role each plays in supporting compliance risk management.  It was published in the January 2015 issue of ABA Bank Compliance magazine.
    Private Student Lending: Time to Meet a Higher Standard
    (Published April 2014) Private student loans are receiving attention from federal and state regulators and enforcement agencies. In February 2014, for example, the CFPB filed a lawsuit against a for-profit college and private student lender accusing the entity of pushing students into higher-cost private student loans that were likely to end in default. This paper is therefore intended to provide guidance to private student lenders to help them meet consumer needs and avoid potentially unfair, deceptive or abusive practices.
    Déjà Vu All Over Again
    (Published March 2014) The Community Reinvestment Act (CRA) was enacted as part of the Housing and Community Development Act of 1977 to combat the “redlining” of neighborhoods where banks were believed to be reluctant or unwilling to lend. Eighteen years later, the initial regulatory framework had outlived its usefulness and was replaced by a new regulatory regime that ostensibly emphasized performance in lending, investment, and services. What are CRA's standards for reviewing performance today?
    Consumer Complaint Management: Understanding Regulatory Expectations
    (Published February 2014) The role of the Consumer Financial Protection Bureau (CFPB) is to receive, record, and process complaints pertaining to financial services offered by banks, thrifts, and other providers of financial services. In this article we will look at complaint handling from the examiner’s point of view and help you identify effective processes that meet or exceed the expectations of the CFPB and the federal banking regulators. The specific elements of an effective complaint management system will vary across institutions, but the key areas to be addressed include complaint intake, escalation, analysis, response, and final resolution.