Dean Stockford - Len Suzio - Podcast Details

Shows

The Compliance 911 ShowTop challenges with Compliance ManagementIn this episode, Dean and Len focus on the top compliance management challenges financial institutions face in 2025, particularly in data privacy, cybersecurity, AI systems, and anti-money laundering/counter-terrorism financing (AML/CTF). They highlight how cyber threats—amplified by advances in AI—require robust encryption, advanced threat detection, and strict consent management. While AI and automation can streamline compliance, risk management, and customer service, they warn of the dangers of data bias and privacy concerns, stressing the need for strong governance and data quality controls. For AML/CTF, ongoing employee training, enhanced due diligence, and AI-driven transaction monitoring are crucial. The...2025-07-1622 min

The Compliance 911 ShowCFPB Extends Section 1071 Compliance DatesIn Episode 98, Dean and Len discuss the CFPB’s newly announced 2025 Section 1071 Interim Final Rule, which further delays the compliance dates for small business lending data collection and reporting by roughly one year for thousands of banks, credit unions, and commercial lenders. The hosts break down the complexities created by shifting rules, changes in definitions of “small business loan,” and the overlap with Community Reinvestment Act (CRA) requirements. They highlight how the new staggered compliance dates and partial-year reporting could create confusion, unnecessary costs, and data that’s not useful for analysis. The podcast encourages lenders to submit comments before t...2025-07-0214 min

The Compliance 911 Show2023 CRA Rule Repeal: Lessons to be LearnedIn the podcast “2023 CRA Rule Repeal: Lessons to be Learned,” Dean Stockford and Len Suzio discuss the potential repeal of the complex 2023 Community Reinvestment Act (CRA) rule and argue that, despite its likely demise, valuable insights can still be drawn from it. Len highlights that the 2023 rule introduced a breakthrough by offering calibrated numerical benchmarks for CRA performance ratings—something previous rules lacked—which gave bankers a clearer way to measure and self-assess their CRA performance against both market and demographic standards. The conversation also notes that, while the new rule provided clarity on how to resolve conflicting performance results...2025-06-1813 min

The Compliance 911 ShowImportance of Compliance Management in times of transitionIn this episode, Dean and Len discuss the critical role of compliance management systems (CMS) within financial institutions, especially during periods of regulatory change and uncertainty. They emphasize that strong CMS is more than just box-checking—it is the foundation for harmonizing policies, monitoring risks, and ensuring ethical operations across departments. The conversation highlights challenges such as evolving regulations, complex financial products, digital assets, and talent shortages, as well as the recent regulatory shifts like the rollback of the 2023 CRA rule and changing CFPB priorities. The hosts stress that proactive, values-driven compliance management helps institutions stay resilient, maintain stability, an...2025-06-0418 min

The Compliance 911 ShowThe fatal flaws in the 2023 CRA ruleIn Podcast 95, Len and Dean delve into the critical flaws of the 2023 Community Reinvestment Act (CRA) rule, emphasizing its detrimental impact on banks and communities. Len highlights the rule's exclusion of crucial loan types like multifamily mortgages and open-end mortgages, arguing they are vital for community development. He criticizes the rule's overly complex performance rating system, which he claims is incomprehensible and undermines its intended purpose. Len urges bankers to actively support the rule's repeal, emphasizing the need for public education and constructive feedback to reshape regulatory policies effectively. Dean underscores the importance of understanding these flaws and advocating...2025-05-2116 min

The Compliance 911 ShowFraud, the silent epidemicIn Episode 94 of their podcast series, Len and Dean discuss the pervasive issue of bank fraud, highlighting its various forms and staggering financial impacts. They cover topics such as credit card fraud, phishing, synthetic identities, and insider threats, citing significant increases in fraud incidents and financial losses globally. Dean provides insights from recent reports, including specific statistics on consumer losses and the rise of different fraud types. They conclude with recommendations for financial institutions to enhance fraud controls through advanced technologies like AI, multi-factor authentication, and secure encryption protocols, emphasizing the importance of customer education and regulatory compliance. 2025-05-0712 min

The Compliance 911 ShowPredictions regarding the 2023 CRA Rule and Section 1071 and how to prepare for expected developmentsIn this podcast, Len and Dean discuss the potential impact of regulatory changes under the Trump Administration, particularly focusing on the 2023 Community Reinvestment Act (CRA) rule and Section 1071 rule. Len highlights significant problems with the 2023 CRA rule, especially the rigid new assessment area rules that could create unrealistic performance standards for banks. The new rule introduces assessment areas for large banks based on entire counties and remote retail lending areas, which could lead to misleading performance evaluations. Len urges the banking community to prepare for potential regulatory changes, provide feedback during the notice of proposed rulemaking, and advocate for...2025-04-1112 min

The Compliance 911 ShowElder Financial ExploitationIn this podcast episode, Len and Dean discuss a recent Joint Statement from regulators on "Elder Financial Exploitation." They explore the challenges financial institutions (FIs) face in protecting seniors from fraud while respecting their independence and privacy rights. Dean highlights key points from the guidance, including policies for governance, employee training, transaction holds, and trusted contacts, aimed at preventing elder financial exploitation. They also discuss the balance between intervention and autonomy, the evolving tactics of fraud, and the role of FIs in reporting suspicious activities. Recommendations for FIs include using AI-driven fraud detection, collaborating with various stakeholders, and providing...2025-04-1115 min

The Compliance 911 ShowThird-Party Risk The competitive world of banking struggles to keep up with technological advances, particularly in a regulatory environment.In this podcast, the hosts discuss the importance of managing third-party risk for financial institutions. They highlight how institutions rely on external providers for technological innovation and operational support, but these partnerships come with a range of risks. Key risk categories include operational, cybersecurity, regulatory, reputational, financial, legal, and concentration risks. To manage these effectively, institutions must engage in comprehensive due diligence, assess their risk appetite, continuously monitor vendor relationships, and ensure that their contracts clearly outline responsibilities and safeguards. The conversation emphasizes that third-party risk management is a complex, ongoing process tailored to the unique needs and size...2025-03-1914 min

The Compliance 911 ShowChanges in the Evolving approach to redliningIn this podcast, Dean and Len discuss potential regulatory changes in 2025, particularly concerning the Community Reinvestment Act (CRA) and Section 1071 of Dodd-Frank. Len outlines five ways regulations can change: congressional legislation, regulatory agency amendments, enforcement changes, litigation, and the Congressional Review Act. He predicts that legislative action is unlikely due to political gridlock but sees regulatory amendments, enforcement shifts, and litigation as probable paths for change, especially with the Trump Administration's focus on deregulation. Len critiques the 2023 CRA Rule for its complexity and rigidity in assessment areas, and he argues that Section 1071 exceeds congressional intent by mandating excessive data...2025-03-0716 min

The Compliance 911 ShowThe Regulatory Situation After the Trump Executive Orders Regulatory Freeze Pending ReviewThe podcast discusses recent regulatory developments following the issuance of an Executive Order by President Trump’s administration that froze regulatory actions. This freeze affects the proposal, issuance, and implementation of rules, pending review by new agency heads. The conversation focuses on the implications for banking regulations, particularly Section 1071 and the 2023 CRA rule, both of which have controversial effective dates approaching. While there is some uncertainty regarding whether these rules fall under the freeze, recent statements from administration officials suggest a delay is likely. Additionally, a congressional repeal effort for Section 1071 adds another layer of uncertainty. The hosts emphasize th...2025-02-2012 min

The Compliance 911 ShowNavigating 2025: Key Compliance Challenges and Regulatory Trends in BankingIn this episode of The Compliance 911 Show, Dean and Len discuss the key regulatory and compliance trends expected in 2025. While a Republican-controlled government may signal potential regulatory easing, changes will take time to materialize, making 2025 a pivotal and costly year for compliance. Key areas of focus include anti-money laundering (AML) and know-your-customer (KYC) regulations, with FinCEN pushing for stricter reporting requirements and global efforts to standardize compliance. AI-powered compliance tools, blockchain, and cybersecurity are also highlighted as both opportunities and risks, with new regulations likely addressing AI bias and data protection concerns. Additionally, banks must enhance third-party risk management...2025-02-1013 min

The Compliance 911 ShowChanges in the Evolving approach to redliningPodcast 87 explores the evolving regulatory approach to redlining enforcement, focusing on shifts since the DOJ launched its “Combatting Redlining Initiative” in 2021. Historically, redlining was assessed based on intent and loan denials, transitioning in 2009 to statistical analyses using "Reasonably Expected Market Areas" (REMA). Recently, regulators have expanded REMAs to entire metropolitan areas or states, raising concerns about fairness and accuracy. A notable development evidenced in some recent examinations is a new peer definition for banks under examination, limiting comparisons to banks and credit unions with deposit-taking branches in the REMA. This adjustment, which excludes mortgage companies operating under different models, has sh...2025-02-0614 min

The Compliance 911 ShowRegulatory environment after the historic election and what we learned from the recent TD Bank penalty.The discussion highlights the potential for regulatory shifts, particularly around CRA and Dodd-Frank 1071, though changes may take 18-24 months. The conversation shifts to the unprecedented $3 billion penalty against TD Bank. In a press release from the Department of Justice, Attorney General Merrick Garland said, "By making its services convenient for criminals, TD Bank became one." The press release also said the TD Bank plea marked "the first instance of a U.S. bank pleading guilty to conspiracy to commit money laundering" and describes a situation in which "TD Bank faced systemic compliance failures, including inadequate in...2025-01-0817 min

The Compliance 911 ShowNavigating the New Compliance Landscape: CRA and Section 1071Welcome to another insightful episode of the Compliance 911 Show! In this episode, hosts Dean Stockford and Len Suzio dive deep into the challenges and impacts of the simultaneous implementation of the new CRA 2023 rule and the Section 1071 rule set to unfold over the next few years. Our discussion focuses on how compliance officers can prepare for these significant changes, including understanding the phased rollout plan, identifying covered lenders, and the implications of reporting requirements under Section 1071. As litigation continues to pose potential delays, our hosts emphasize the importance of getting a head start on compliance...2024-12-0417 min

The Compliance 911 ShowFDIC Advertising & Signage rule changesIn this podcast, Dean Stockford and Len Suzio discuss the recent FDIC Advertising and Signage rule changes, which took effect on April 1, 2024, and aim to modernize compliance requirements to align with digital banking practices. Dean highlights the importance of these updates, which include modernized signage rules for branches, digital platforms, and ATMs, disclosures distinguishing insured deposits from non-deposit products, and mandatory written policies for compliance. The rule also addresses misrepresentations about FDIC insurance by IDIs and non-bank entities, clarifying disclosure requirements to prevent consumer confusion. With a mandatory compliance date of May 1, 2025, Dean urges institutions to act promptly to...2024-12-0416 min

The Compliance 911 ShowTeaching about the New Community Reinvestment Act with Linda EzukaIn this episode of the Compliance 911 Show, hosts Dean Stockford and Len Suzio are joined by special guest Linda Ezuka for the second part of their series on the Community Reinvestment Act (CRA). Linda, the founder of CRA Today and the CRA Hub, shares her extensive expertise on CRA compliance, community development finance, and the new CRA rules introduced in 2023. The discussion delves into the complexities and challenges posed by the new CRA regulations, including the concerns expressed by bankers about adapting to these changes. Linda provides valuable insights into how financial institutions can prepare for the...2024-11-1419 min

The Compliance 911 ShowMastering the Community Reinvestment Act with Linda EzukaWelcome to the Compliance 911 Show, where hosts Dean Stockford and Len Suzio dive into the intricacies of the Community Reinvestment Act (CRA) with special guest Linda Ezuka. Linda, the founder of CRAtoday and the CRAhub, shares her extensive experience and insights on how to master CRA compliance, stay exam-ready, and leverage capital for community development. In this episode, Linda discusses the most common questions from bankers, the importance of performance context, and the challenges of identifying community development loans. She also emphasizes the need for CRA professionals to engage with their communities to truly understand and meet...2024-10-1818 min

The Compliance 911 ShowRed Warning on Redlining: Looking AheadIn Episode 81 of the podcast series "Red Warning on Redlining," Len and Dean continue their discussion with fair lending expert Lori Sommerfield, a partner at Troutman Pepper. They explore the future of redlining enforcement by DOJ and federal agencies through 2024 and beyond. Lori explains the Combatting Redlining Initiative's impact to date and coordination among the federal agencies, as well as advises financial institutions on best practices to monitor and manage redlining risks. Implications of the U.S. Supreme Court's recent Loper Bright decision for redlining cases is also discussed. The episode emphasizes preparation and fair lending compliance for financial...2024-09-0519 min

The Compliance 911 ShowRed Warning on Redlining: Looking BackIn Episode 80 of the podcast series on regulatory compliance, Len and Dean discuss the topic of redlining with Lori Sommerfield, a partner at Troutman Pepper, in a new two-part series “Red Warning on Redlining.” Lori, a seasoned fair lending attorney, explains the traditional and modern definitions of redlining, emphasizing how regulators now primarily use Home Mortgage Disclosure Act (HMDA) data to identify potential redlining activity without other evidence to support such claims. She also discusses the DOJ's "Combatting Redlining Initiative," which is a “whole of government” approach leveraging federal agencies, U.S. attorneys, and state attorneys general to eradicate redlinin...2024-08-1416 min

The Compliance 911 ShowRedlining Isn’t What it Used To BeIn a recent podcast, Len and Dean discuss the June 10 article "Manufacturing Fair Lending" from National Mortgage Professional, which delves into the "Modern Theory of Redlining" introduced by bank regulators after AG Merrick Garland's 2021 Combatting Redlining Initiative was announced. The article includes insights from notable figures like Paul Hancock former chief of the Housing and Civil Enforcement at the DOJ and Brian Montgomery, former deputy secretary of HUD highlighting concerns about the government's push for racial balance in loan originations. Len also mentions his follow-up article, "Redlining Isn’t What it Used to Be," which criticizes regulators' use of statistics...2024-07-3111 min

The Compliance 911 ShowElder Abuse-Financial Exploitation and FraudLen and Dean discuss the alarming issue of elder abuse in their 78th and 79th podcasts. Dean expresses concern, especially since he has elderly parents, and highlights recent statistics from FinCEN and the FBI on elder exploitation. Financial institutions reported over $27 billion in elder exploitation between June 2022 and June 2023. The abuse is categorized into elder scams and theft, with scams being more prevalent. The FBI's report for 2023 shows a significant increase in scams targeting individuals aged 60 and older, causing over $3.4 billion in losses. Dean recommends reviewing FinCEN and CFPB guidelines to combat elder financial exploitation and acknowledges the FBI's...2024-07-2510 min

The Compliance 911 ShowThe Court Decides But it Ain’t Over Till It’s OverIn "Podcast 77: The Court Decides But it Ain’t Over Till It’s Over," Dean and Len discuss the recent Supreme Court ruling on the Consumer Financial Protection Bureau (CFPB)'s funding, which upheld its constitutionality, much to the disappointment of many bankers who hoped for its dissolution. Despite this decision, other legal challenges to CFPB's regulations remain unresolved. Specifically, the podcast delves into ongoing litigation concerning Section 1071, which involves the CFPB's new rules for small business lending data collection. The discussion covers the timeline for compliance, the complex issues around additional data points required by the CFPB, and the...2024-07-0912 min

The Compliance 911 ShowFlood Basics still causing pain for someThis podcast discusses flood regulations for institutions lending money on properties. While there are many federal laws, some key ones being the National Flood Insurance Act of 1968 and the Flood Disaster Protection Act of 1973, institutions must comply to avoid penalties. This includes checking if a property is in a flood hazard area, notifying the borrower and requiring flood insurance if necessary, properly handling escrows and monitoring, and even force-placing insurance if the borrower lets it lapse. Common violations include weak internal controls, issues with contents coverage, mistakes in timing and notification, miscalculations of coverage amounts, and failing to properly...2024-06-2513 min

The Compliance 911 ShowRedlining Complications Caused by Implementation of 2020 Census TractsIn this podcast episode, Dean and Len discuss the complexities surrounding redlining accusations faced by banks, particularly focusing on the implications of the 2020 Census data. Len explains that the increase in the number of census tracts and changes in their minority status have created challenges for banks, especially since these changes were announced late into 2022. He highlights how these complications can impact a bank’s compliance with anti-redlining regulations, as loan applications could be affected by tract status changes during processing. Len advises banks to proactively analyze the impact of new and altered tracts on their lending practices to be...2024-06-1112 min

The Compliance 911 ShowDiscrimination and Bias in Residential LendingIn this podcast episode, Dean and Len discuss the timely issue of appraisal discrimination and bias within the context of Fair Lending. Dean highlights the FFIEC's recent guidance on mitigating risks related to discriminatory practices in property valuations and ensuring credible appraisals. Appraisal bias, which can result in minorities receiving lower property valuations, affects credit access and terms and violates anti-discrimination laws like the Equal Credit Opportunity Act and Fair Housing Act. The guidance is relevant for both financial institutions and examiners, emphasizing the importance of internal controls and compliance to avoid legal risks and ensure fair lending practices...2024-06-0212 min

The Compliance 911 ShowThe Texas Court’s Preliminary Injunction Against the 2023 RuleIn Podcast 73, Dean and Len discuss a recent preliminary injunction issued by a Texas federal judge against the 2023 Community Reinvestment Act (CRA) rule. This injunction has halted the implementation of the new rule, pending legal proceedings. The court found substantial grounds suggesting the federal banking regulators may have exceeded their authority in expanding CRA evaluation markets and including deposits and other retail banking products under the regulation. The court's decision highlighted four key reasons for this view: the inconsistent interpretation of "entire community" in the new rule, the questionable authority to regulate beyond credit activities, the application of the "...2024-04-2312 min

The Compliance 911 ShowClimate Risk, the emerging riskThis episode of the podcast, focusing on climate risk as an emerging regulatory compliance issue, features a dialogue between Len and Dean. They discuss how climate-related risks, especially in the financial sector, have gained attention in recent years. New York State is highlighted for its proactive stance in providing guidance for financial institutions on managing these risks, including a section published on the NYDFS website. Dean emphasizes the lack of specific regulations but notes earlier general principles issued by the OCC regarding climate-related financial risk management. They also delve into the use of data and mapping techniques to assess...2024-04-1517 min

The Compliance 911 ShowHow to estimate how your performance will look under the new CRAPodcast #71 discusses how banks can estimate their performance under the new Community Reinvestment Act (CRA) rules. Len highlights bankers' concerns about the increased difficulty in passing the CRA exam with the new rules, which predict a significant rise in failure rates. He emphasizes the importance of the Retail Lending Test, explaining that failing this test results in an overall unsatisfactory CRA rating.To estimate their performance, banks should first focus on the Retail Lending Test and identify their Retail Lending Assessment Areas. The next steps involve determining benchmarks based on geographic and borrower distribution tests and applying multipliers to...2024-03-2614 min

The Compliance 911 Show2024 Regulatory Hot TopicsEpisode 70 of "Compliance 911, show" titled "2024 Regulatory Hot Topics," discusses the major regulatory challenges facing financial institutions in 2024. Hosts Len and Dean mark their 70th episode, reflecting on various topics covered over the series. They delve into significant regulatory changes including the Community Reinvestment Act (CRA) reforms and Dodd-Frank 1071 rules, highlighting their impact on banks and the ongoing lawsuits challenging these regulations. Additionally, they touch on proposed changes to the Fair Credit Reporting Act (FCRA), slow progress in Anti-Money Laundering rulemaking, and new standards for Automated Valuation Models (AVMs). The episode also covers updates in Fair Lending, digital adaptations for FDI...2024-03-1614 min

The Compliance 911 ShowElectronic Funds Transfers-The Investigation ProcessEpisode 68 of the podcast discusses the investigation process for Electronic Funds Transfers (EFT) under the Electronic Fund Transfer Act. The hosts, Dean and Len, emphasize the importance of consumer protection in EFT and remittance transfers, outlining the process for consumers to dispute unauthorized or incorrect transactions. They stress that financial institutions must promptly begin investigating disputes upon receiving notice, either oral or written, from the consumer. The regulation mandates strict timelines for these investigations, with institutions having 10 business days to investigate, extendable to 45 or 90 days for certain cases if provisional credit is provided. The episode highlights the need for...2024-02-2812 min

The Compliance 911 ShowThe Coming Perfect StormPodcast #69, "The Coming Perfect Storm," features a discussion between Dean and Len Suzio about new regulatory challenges for the banking sector. Len highlights the implications of two key regulations: Section 1071 of the Dodd-Frank Act and the new Community Reinvestment Act (CRA) rule. Section 1071 requires detailed reporting of small business lending data, including race and ethnicity of borrowers, to the Consumer Financial Protection Bureau. The revised CRA rule emphasizes the impact of fair lending issues on a bank's CRA rating and introduces more stringent criteria for evaluating discriminatory or illegal credit practices. Len expresses concerns about the potential...2024-02-2009 min

The Compliance 911 ShowThe New CRA II - Retail Lending Test"The New CRA" features a discussion between Dean Stockford and Len Suzio about the recent changes in the Community Reinvestment Act (CRA) regulations. Len has dedicated significant time to understanding the new CRA rule, which is a lengthy 1,494 pages, and has even published articles on the topic. He describes the new rule as an "unmitigated disaster for the banking industry," a conclusion drawn not from his personal opinion but from the regulators' own data. The new CRA rule significantly increases the failure rate of CRA exams for banks, estimated to be 10-12%, up from the long-term average...2024-01-3113 min

The Compliance 911 ShowECOA Credit Denial and the use of AIIn this podcast, Dean and Len discuss the September guidance from the CFPB concerning the Equal Credit Opportunity Act (ECOA), credit denials, and Artificial Intelligence (AI). The guidance emphasizes that lenders using AI for credit decisions must provide specific and accurate reasons for adverse actions. This includes updates to sample adverse action forms and checklists to reflect actual reasons for credit denials or changes in conditions. The discussion also touches on potential updates to Home Mortgage Disclosure Act (HMDA) data collection to align with these expanded reasons for adverse action. Dean advises lenders to update ECOA assessments, review policies...2024-01-1711 min

The Compliance 911 ShowThe New CRA - IIn Podcast #65 titled "The New CRA", Dean and Len discuss the recent changes introduced in the new Community Reinvestment Act (CRA) published just over a week ago. Len highlights three significant changes: the reclassification of bank categories based on their assets; the transformation in assessment areas which now include "facility-based assessment areas", "retail lending" assessment areas, and "outside retail lending areas"; and the modification in performance tests and standards. Particularly, the changes in bank categories mean that small banks are those with assets less than $600 million, intermediate banks have assets ranging from $600 million to less than $2 billion, and large...2024-01-0314 min

The Compliance 911 ShowReg. CC-Funds Availability, it ’s a good time to revisit the hold provisions and timing for Reg. CC.In episode 64 of the Compliance 911 podcast, hosts Len Suzio and Dean Stockford discuss the intricacies of Reg. CC, a regulation that deals with funds availability. Dean emphasizes the importance of understanding the definitions within regulations as the same word or phrase might carry different meanings in different contexts. He goes on to explain that Reg. CC was implemented to enforce the provisions of the Expedited Funds Availability Act of 1987, which set the rules for when a bank had to make deposited funds available to depositors. The regulation is highly technical and mandates strict timing provisions based on factors such...2023-12-2012 min

The Compliance 911 ShowThe Importance of Assessment AreasIn the podcast, Len Suzio from GeoDataVision LLC and Dean Stockford of M&M Consulting delve into the topic of CRA (Community Reinvestment Act) Assessment Area delineation. Len emphasizes the critical importance of banks updating their CRA assessment area maps, particularly in light of changes to census tracts that were officially adopted by the FFIEC on January 1, 2022. He is alarmed to find that many banks haven't updated their maps, which is a mandatory requirement. Len further elaborates on the "performance context" in the CRA regulation, which is pivotal in determining banks' performance expectations. This context includes the unique characteristics...2023-12-0611 min

The Compliance 911 ShowElectronic Funds Transfers-The BasicsEpisode 62 of the podcast delves into the intricacies of Electronic Funds Transfers, primarily focusing on the basics of Regulation E (Reg. E) Error Resolution provisions and their stringent timelines for addressing claims. Dean Stockford and Len Suzio begin by discussing the impact of their previous podcasts, with Dean emphasizing the importance of understanding the Electronic Fund Transfer Act, which establishes the basic rights, responsibilities, and liabilities of consumers and financial institutions engaging in electronic fund transfers. Dean outlines the specific definitions of "Electronic Fund Transfer," explaining that it includes activities such as Point-of-sale transfers, ATM transfers, direct deposits or...2023-11-2212 min

The Compliance 911 ShowWhat’s behind the increase in CRA Exam failures?On a broadcast hosted by Dean Stockford, Len Suzio highlights the increase in adverse Community Reinvestment Act (CRA) ratings for banks in the first half of 2023. An article from Standard & Poor indicated that 12 banks received less than satisfactory performance ratings, a jump compared to 14 for the entirety of 2022. Len believes that this rise can be attributed to regulators enforcing stricter performance standards. Evidence for this includes the proposed new CRA Rule, which intends to set higher CRA performance standards. An analysis by bank regulators shows that the new rule would result in a significant increase in the CRA exam...2023-11-0810 min

The Compliance 911 ShowElectronic Funds Transfers-what you need to know when using cash applications such as VenmoLen and Dean focus on Electronic Funds Transfers, particularly person-to-person (P2P) payment apps like Venmo, Apple Pay, and Zelle. Dean elaborates on the December 2021 update by the CFPB to the Reg. E FAQs. These guidelines stress that P2P payments, when they involve certain methods like a consumer’s debit card, are subject to the provisions of EFT-Regulation E. The Electronic Funds Transaction Act (EFTA) and Regulation E define an EFT and set the framework for how EFTs involving consumers should work. Dean also clarifies that the rights, liabilities, and rules for users of these apps are dictated by the EFTA and...2023-10-3012 min

The Compliance 911 ShowStatistical Measurements of complianceIn this podcast episode, Dean and Len delve into pivotal questions concerning regulatory compliance in the banking sector. Len highlights the two primary questions every compliance and risk officer should ponder: whether their lending performance meets the expectations of examiners and if the performance is statistically significant. The conversation comes against the backdrop of changes to the Community Reinvestment Act (CRA) Rule and the Department of Justice's recent focus on the "Anti-Redlining Initiative." Len breaks down the proposed CRA rule, emphasizing performance benchmarks and their significance for banks to ascertain their ratings even before official examinations. ...2023-10-1115 min

The Compliance 911 ShowKeeping up with all the new regulationsIn this podcast episode, Len and Dean discuss the challenges compliance officers face in keeping up with regulatory changes and guidance. They mention various regulations and topics that have been covered in previous episodes, such as CRA, Fair Lending, Redlining, BSA, AI, and more. They emphasize the importance of staying informed about regulatory changes and offer some techniques for compliance professionals to do so, including creating a regulatory calendar, attending conferences, reviewing internal processes, using compliance software, and building a team. Dean then provides a specific example of recent guidance from the CFPB in June 2023 regarding the...2023-09-2712 min

The Compliance 911 ShowCombatting Redlining InitiativeIn this podcast episode, Len Suzio and Dean Stockford discuss the implications of the DOJ’s “Combatting Redlining Initiative" that was announced in 2021 and the ensuing increase in redlining referrals from bank regulators to the DOJ in 2022. Len believes this issue represents a significant regulatory compliance risk for banks, despite not being convinced of the DOJ's claim of widespread redlining practices today. Len's primary concern is the alleged misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators, which, in his view, has misleadingly expanded a bank’s Community Reinvestment Act (CRA) assessment area to include markets that ar...2023-09-1321 min

The Compliance 911 ShowArtificial Intelligence (AI) and BankingIn this podcast episode, Len Suzio and Dean Stockford discuss the unregulated use of Artificial Intelligence (AI) in the banking industry. Dean brings up how, amidst the focus on fair lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP), there have been increasing concerns about potential bias in AI systems. Specifically, red flags have been raised about scoring systems built into the lending process and the potential for inadvertent redlining in marketing systems. Both Len and Dean concur on the importance of understanding and regulating the use of AI in banking systems. Dean suggests several proactive...2023-08-3008 min

The Compliance 911 ShowUnveiling the Implications: How Section 1071 Reshapes Community Reinvestment Act ReportingIn this podcast episode, Dean and Len discuss the implications of the new Section 1071 rule, which extends beyond the banking community. Len highlights that the number of reporters under Section 1071 is estimated to be four times greater than under the Community Reinvestment Act (CRA). They focus on the impact of Section 1071 on CRA reporting. Len mentions that the Office of the Comptroller of the Currency (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced their intention to replace the reporting of small business and small farm loans under CRA with Section 1071 reporting. Additionally, the definition of...2023-08-2114 min

The Compliance 911 ShowBack to ERM BasicIn a podcast, hosts Len and Dean discussed the heightened focus on Enterprise Risk Management (ERM) within financial institutions. They highlighted the regulatory pressure spurred by issues like compliance, bank failures, Climate Risk, ESG factors, and political influences. Dean pointed out common gaps in ERM policies, such as lack of coverage for technology systems, strategic plans, and talent management. He advised that ERM policies should emphasize data and technology structures for reporting, mention strategic plans, and reference "Talent Management" for skill enhancement. The conversation concluded with a recommendation for risk managers and senior executives to review and e...2023-08-0208 min

The Compliance 911 ShowSection 1071In this podcast episode, Dean and Len discuss the Section 1071 Rule, which is the hottest regulatory topic in the financial industry. Len provides an overview of the rule and its implications for lenders. Covered lenders, which include any financial institution that originates 100 or more covered loans for two consecutive years, will need to maintain a data collection system to report on their commercial lending activity. Len also emphasizes the importance of distinguishing between covered and non-covered transactions and being careful about protected demographic information, such as the race, ethnicity, and sex of the principals of the business. The podcast...2023-07-0313 min

The Compliance 911 ShowFair Lending Examiner ExceptionsThis podcast episode discusses Fair Lending and focuses on examiner comments and specific examples of issues from regulators. The hosts, Len and Dean, discuss a scenario where a Compliance Officer or Fair Lending Officer in a community bank reviews loans for evidence of disparate treatment (Redlining). They find a series of portfolio loans where the borrowers received more favorable terms in the form of a better rate, and in each case, all were white men applying alone. Upon further review, they find that these exceptions were never submitted to the loan committee for approval, which is required by policy.2023-06-1912 min

The Compliance 911 ShowCommunity Development under CRAIn this episode of Podcast 51, hosts Dean and Len discuss the complexities of community development under the Community Reinvestment Act (CRA). They outline the four different definitions that qualify for community development credit: affordable housing, community services, economic development, and revitalization/stabilization. Len provides an in-depth explanation of each definition and shares tips for maximizing community development credit. They also discuss common misconceptions about claiming credit for community development activities outside assessment areas. Len emphasizes the importance of claiming credit for all qualified community development activities, as it can contribute to a higher performance rating under CRA...2023-06-0516 min

The Compliance 911 ShowFair Lending Appraisal BiasIn Episode 50 Len and Dean explore the issue of Fair Lending as it relates to appraisal bias. This emerging issue can lead to illegal discrimination within the appraisal process, impacting generational wealth building for minority consumers. Len and Dean discuss appraiser independence, the 2008 financial crisis, and how lenders can protect themselves against appraisal bias and potential liability under ECOA and FHA. Suggestions include thorough vendor due diligence, incorporating appraisal bias risks into fair lending risk assessments, training personnel on fair lending and appraisal bias red flags, and establishing clear processes for reconsiderations and appraisal complaints. Tune in to this...2023-05-2216 min

The Compliance 911 ShowImpending Changes to CRA & imminent publication of Dodd-Frank Section 1071 RuleIn Podcast 49, Dean Stockford and Len Suzio discuss the impending changes to the Community Reinvestment Act (CRA) and the imminent publication of the Dodd-Frank Section 1071 Rule. The CRA Rule's publication date remains uncertain, while the Consumer Financial Protection Bureau (CFPB) is under court order to publish the Section 1071 Rule by March 31. Len notes that the 1071 Rule, which will have profound implications for the financial services industry, has been 15 months in the making and is expected to be quite controversial. Unlike CRA, Section 1071 is a reporting mandate, much like the Home Mortgage Disclosure Act (HMDA) regulations, and will be used for...2023-04-2512 min

The Compliance 911 ShowBSA BasicsIn this podcast episode, Len Suzio and Dean Stockford discuss the basics of the Bank Secrecy Act (BSA) and the importance of having a sound BSA program. They break down the extensive provisions of the BSA into two parts - the Basic Stuff (BS) and the Additional (A), which is pre and post 9/11. They also highlight the areas of high risk for non-compliance, including suspicious activity monitoring, SAR referral programs, and customer due diligence. This podcast is informative for those who want to understand the basics of BSA and its importance in maintaining safety and soundness in financial institutions.2023-04-2419 min

The Compliance 911 ShowREMA’s: Their Use and Abuse by Regulators in the war against redliningIn this podcast, Len Suzio discusses his concerns about the threat posed to banks by the misuse of the concept of Reasonably Expected Market Areas (REMA) by regulators in their fight against redlining. The DOJ's "Combatting redlining initiative" launched in October 2021 is one such example. Len highlights that the concept of REMA has no origin in law or regulation, making it vague and open to interpretation, which can lead to potential abuse. Regulators often determine a bank's REMA based on factors like marketing campaigns, market plans, media usage, and self-produced promotional materials. If a bank's REMA is...2023-04-0512 min

The Compliance 911 Show2023 Regulatory Hot TopicsIn Episode 46 of the podcast series, Len and Dean discuss the 2023 regulatory hot topics facing financial institutions. They touch on multiple re-presentment fees, Dodd-Frank 1071 and its implications for small business data collection, and the forthcoming Cyber Security reporting requirements under the Critical Infrastructure Act of 2022. Climate risk is also identified as a significant area of focus for financial institutions, even for those below the $100 billion asset threshold. Lastly, they highlight fair lending, fraud, and potential changes to Reg. E as additional areas of interest for 2023. Throughout the episode, the hosts emphasize the importance of being proactive and staying informed...2023-03-1717 min

The Compliance 911 ShowPending CRA Proposed RuleThis podcast deals with the big problems in the proposed CRA Rule. In it we discuss the 3 possible grounds for legal challenge if the Rule should be adopted as proposed. We also talk about the 3 most significant impacts of the proposed rule. Brought to you by GeoDataVision and M&M Consulting 2023-03-1713 min

The Compliance 911 ShowWhile Fair Lending remains a hot topic, do not forget about the technical provisions of ECOA and FHA.While Fair Lending remains a hot topic, do not forget about the technical provisions of ECOA and FHA. Brought to you by GeoDataVision and M&M Consulting 2023-02-1023 min

The Compliance 911 ShowThe coming Climate Risk RegulationsClimate Risk Regulations are Coming. Learn what regulators are doing and how you can identify climate risk for 19 different natural hazards for your bank. Brought to you by GeoDataVision and M&M Consulting 2022-12-2713 min

The Compliance 911 ShowOverdraft programs and Junk fees, what you need to knowOverdraft programs and Junk fees, what you need to know featuring Dean Stockford and Len Suzio. Brought to you by GeoDataVision and M&M Consulting 2022-12-1909 min

The Compliance 911 ShowMaxine Waters CRA Surprise: HR 8833Congresswoman Maxine Waters has submitted legislation that would amend the original Community Reinvestment Act in radical ways. Learn about her proposal for mandatory "Community Advisory Committees" and their role with bank management as well as other radical aspects of the proposed legislation in this broadcast. Brought to you by GeoDataVision and M&M Consulting 2022-11-0212 min

The Compliance 911 ShowCompliance Management Systems in 2022This podcast focuses on Compliance Management Systems. With everything coming at us from CRA, Fair Lending and UDAAP, it is imperative that financial institutions revisit CMS to ensure effective management. Brought to you by GeoDataVision and M&M Consulting 2022-10-1818 min

The Compliance 911 ShowHow is the CRA Rule being enforced in the field?In this podcast, CRA expert Len Suzio explains how the CRA is being applied in the field with respect to Assessment Areas. The trend is for regulators to insist on expanded Assessment Areas which can dramatically increase the potential for failing a CRA exam due to inflated and unrealistic performance standards associated with Assessment Areas that a bank's branch network is not structured to serve. Don't miss this important topic. Be prepared for regulator pressure on your Assessment Area configuration! Brought to you by GeoDataVision and M&M Consulting 2022-10-0517 min

The Compliance 911 ShowFair Lending remains are of interest for regulatorsFair Lending remains a hot area of interest for regulator’s. Brought to you by GeoDataVision and M&M Consulting 2022-09-1417 min

The Compliance 911 ShowThe new 2022 Census Tracts and their Impact on Banks.This podcast covers the implementation of the new 2020 Census tracts effective January 1, 2022. It covers the impact of the new tracts for CRA in terms of the Community Reinvestment Act and Fair Lending. The new tracts are effective retroactive to the beginning of 2022. Brought to you by GeoDataVision and M&M Consulting 2022-08-2513 min

The Compliance 911 ShowUDAAP and CFPB Application of Unfairness`This podcast will discuss the CFPB’s new application of Unfairness under UDAAP. Brought to you by GeoDataVision and M&M Consulting 2022-07-2019 min

The Compliance 911 ShowFlood Violations Continue to SurgeThis podcast will highlight ongoing flood issues as violations continue to surge. Brought to you by GeoDataVision and M&M Consulting 2022-07-0615 min

The Compliance 911 ShowUrgent 🔥🔥The 2022 CRA NPR description🔥🔥This podcast addresses the most significant aspects of the 2022 CRA NPR, including the projected 500% increase in CRA Exam failure rates detailed in the NPR. In the podcast noted CRA expert Len Suzio discusses the "Double Jeopardy" for Intermediate banks and the "Double Whammy" for Large banks including the most radical changes in Assessment Area delineation and the "Calibrated" performance rating scale. Mr. Suzio warns about the 500% increase in CRA exam failure rates projected by the Agencies based on the implementation of the NPR and what are the factors precipitating such an adverse impact. This is a must-listen-to podcast for every ba...2022-06-2319 min

The Compliance 911 ShowUnderstanding the Bank CRA Size Categories and the Transition RulesMany bankers are casual about understanding the different bank size categories in the application of the CRA regulations. But transitioning from one size category to another has profound implications that banks need to understand and prepare for. In this podcast CRA expert Len Suzio goes beyond explaining the different size categories. He explains what happens and when it happens as a bank moves from one size category to another. Brought to you by GeoDataVision and M&M Consulting 2022-06-0217 min

The Compliance 911 ShowPeak inside Fair Lending regulatory enforcement for 2022This podcast will give you a peak inside the current regulatory arena. Brought to you by GeoDataVision and M&M Consulting 2022-05-2009 min

The Compliance 911 ShowA new insight into PPP loans and their potential impact on CRA performanceA new insight into PPP loans reveals that it may be easier to substantiate them as qualified community development loans. One of the 4 different definitions of community development under CRA is the "economic development" definition. To be qualified for economic development a PPP loan had to meet the "size" test and the "purpose" test. However, banks were not required to collect the gross annual revenues of a PPP loan borrower and therefore did not have the data to substantiate whether the borrower met the size test. Noted CRA expert Len Suzio points out that all PPP loans had to m...2022-05-0308 min

The Compliance 911 ShowOverdraft Protection Programs and UDAAP implicationsThis podcast discusses recent enforcement issues with Overdraft programs and UDAAP implications. Brought to you by GeoDataVision and M&M Consulting 2022-04-1611 min

The Compliance 911 ShowComparatorsFor many years bankers have wondered if there is a safe harbor under the various CRA tests but regulators would never comment on or disclose anything in response to questions about this matter. However, the 2020 NPR issued by the FDIC and the OCC and the 2020 ANPR proposed a concept the regulators called "comparators" that established a bright line for minimum performance that would rate as "satisfactory" performance for CRA examination purposes. Listen to CRA expert Len Suzio explain what the concept entails and how it would be calculated. Although not yet adopted, it gives insight into what Len describes...2022-03-3008 min

The Compliance 911 ShowClimate Risk, an emerging hot topicThis podcast will give you a peek inside the emerging hot topic with regulators for 2022, climate risk. Brought to you by GeoDataVision and M&M Consulting 2022-03-1611 min

The Compliance 911 ShowPPP Loans: the Final WordPPP loans may be a thing of the past but they can still have a very big impact on your CRA performance in your next CRA exam. This podcast will cover the big impact PPP loans could have on your CRA performance rating and what you can still do to maximize that impact. Brought to you by GeoDataVision and M&M Consulting 2022-03-0213 min

The Compliance 911 ShowBSA & Banking Marijuana Related BusinessesThis podcast will address minimum due diligence and banking marijuana related businesses and customers. Brought to you by GeoDataVision and M&M Consulting 2022-02-2621 min

The Compliance 911 ShowImportant CRA Resolutions for 2022This podcast covers CRA practices that nationally recognized CRA expert Len Suzio recommends for every CRA officer and bank to implement. Brought to you by GeoDataVision and M&M Consulting 2022-02-2212 min

The Compliance 911 ShowCyber Security Risk Reminders Headed into Holiday season and a peak into 2022 risk management hot topicsThis podcast will cover high risk cyber risk areas headed into the holiday season and give you a snapshot of what hot risk topics we will see in 2022. Brought to you by GeoDataVision and M&M Consulting 2022-02-0712 min

The Compliance 911 ShowUDAAP an emerging hot topic.This podcast will highlight the challenges and regulatory expectations with UDAAP. Brought to you by GeoDataVision and M&M Consulting 2022-01-1913 min

The Compliance 911 ShowShould a Bank Voluntarily Report its CRA data? Here are 7 Good ReasonsLearn about why small banks and especially Intermediate-Small Banks should voluntarily report their CRA activity. Brought to you by GeoDataVision and M&M Consulting 2022-01-0709 min

The Compliance 911 ShowConfusion in CRA – the Devil Really is in the DetailsThe old saying, "The devil is in the details" really applies to CRA. Listen to CRA expert Len Suzio discuss some of the common mistakes and areas of confusion regarding the Community Reinvestment Act. Don't make the mistakes made by many bankers. Brought to you by GeoDataVision and M&M Consulting 2021-12-2813 min

The Compliance 911 ShowIntegrating Climate Change risk into your overall ERMThis podcast will discuss integrating climate risk into your Enterprise Risk Management framework. Brought to you by GeoDataVision and M&M Consulting 2021-12-1111 min

The Compliance 911 ShowHow to prepare for your Fair Lending exam?This podcast will cover the Fair Lending exam process and prep. Brought to you by GeoDataVision and M&M Consulting 2021-11-1918 min

The Compliance 911 ShowWhat will the new CRA look like?The OCC is retracting its 2020 CRA Rule and it is expected the Agency will join the FDIC and the Fed when they issue a new joint notice of proposed rule-making for CRA during 2021. So what might the "new modern" CRA look like? There's plenty of insight to be gained by looking at the soon to be retracted OCC Rule and the CRA ANPR published by the Fed late in 2020. The CRA rules regarding CRA Assessment Areas are sure to be changed with the potential to add new "deposit-based" assessment areas. Bank's are likely to be required to geocode deposits...2021-11-0412 min

The Compliance 911 ShowWhat you need to know about Insider Lending.What you need to know about Insider Lending. This podcast will highlight the important aspects of insider lending. Brought to you by GeoDataVision and M&M Consulting 2021-10-1812 min

The Compliance 911 ShowThe OCC proposes to rescind the 2020 CRA RuleThe OCC has now issued a Notice of Proposed Rule Making regarding the OCC's 2020 CRA Rule. The NPR proposes rescinding the 2020 Rule, but retaining some of its elements. The Public Comment Period ends October 29. This podcast discusses the NPR and identifies what banks may want to submit before the comment deadline. Brought to you by GeoDataVision and M&M Consulting 2021-09-3015 min

The Compliance 911 ShowMore confusion about PPP loansThere continues to be much confusion about PPP loans and their impact on CRA Performance Evaluations. Nationally recognized CRA expert Len Suzio explains the various ways in which PPP lending can significantly impact a bank's CRA performance rating. Whether its community development performance or the small business lending "borrower characteristics" test, Len covers the bases to help bankers understand exactly how PPP lending can and will affect your next CRA exam Brought to you by GeoDataVision and M&M Consulting 2021-09-1510 min

The Compliance 911 ShowECOA/FHAThis podcast will address the technical regulatory provisions for treatment of credit applications under ECOA/FHA. Brought to you by GeoDataVision and M&M Consulting 2021-09-0114 min

The Compliance 911 ShowA Very Serious and Growing CRA Assessment Area ProblemIn this podcast CRA expert, Len Suzio talks about the growing number of banks that fail to pass the Assessment Area ratio test and the negative implications for their entire CRA performance rating. More and more community banks are adopting regional and in some cases, national loan markets seriously diluting the ratio. Examiners' CRA manuals state that a bank cannot be rated "satisfactory" with less than 50% of their loans within their Assessment Areas. Learn about what this means and how to address the problem should your bank be pursuing a similar non-traditional marketing strategy. Brought to you...2021-08-1608 min

The Compliance 911 ShowEnterprise Risk ManagementThis session on Enterprise risk management (ERM) includes the methods and processes used by financial institutions to manage risks and seize opportunities related to the achievement of their objectives. Brought to you by GeoDataVision and M&M Consulting 2021-08-0409 min

The Compliance 911 ShowCRA Tips and Tricks for Intermediate-Small BanksIn this podcast CRA expert Len Suzio shares some tips for Intermediate-Small Banks for CRA purposes. Len reviews the difference between Large Bank CRA examination standards and ISB standards and he shows how ISB's can avoid the Community Development trap. Len also explains the one circumstance in which ISB examination standards may be preferable for ISB's. Brought to you by GeoDataVision and M&M Consulting 2021-08-0409 min

The Compliance 911 ShowOverview of Flood Insurance RequirementsThis podcast provides an overview of requirements for the purchase of mandatory flood insurance. Brought to you by GeoDataVision and M&M Consulting 2021-07-0812 min

The Compliance 911 ShowCRA MistakesIn this podcast, Len Suzio identifies some of the more serious and common CRA mistakes made by banks and explains the troubles they lead to. Lack of preparation for a CRA exam, careless Assessment Area delineation and misunderstanding Community Development all can lead to big problems. Brought to you by GeoDataVision and M&M Consulting 2021-06-2810 min

The Compliance 911 ShowFair Lending and Commercial ApplicationsThis Podcast will discuss Small Business Lending Data Collection Rulemaking for Fair Lending. Brought to you by GeoDataVision and M&M Consulting 2021-05-2711 min

The Compliance 911 ShowAssessment Area delineation your most important CRA decisionCRA expert Len Suzio explains why how you delineate your Assessment Area affects not only your results, but the standards against which you will be compared. Don't determine your Assessment Area until you know how it will affect your performance expectations! Brought to you by GeoDataVision and M&M Consulting 2021-05-1209 min

The Compliance 911 ShowFair Lending in 2021This podcast is focused on regulatory changes and regulatory expectations for Fair Lending in 2021. Brought to you by GeoDataVision and M&M Consulting 2021-04-2010 min

The Compliance 911 ShowWhat Community Development really means under CRACommunity Development is an important performance requirement for Large Banks and Intermediate-Small banks' performance under CRA. But it is frequently misunderstood because it has a highly technical definition. In this podcast, CRA Expert Len Suzio covers the different technical meanings and precise definitions of Community Development as it is applied for CRA purposes. What exactly is "affordable housing", "community services", "economic development", and "revitalization/stabilization" under CRA? To find out the details listen to this podcast featuring noted CRA expert Len Suzio Brought to you by GeoDataVision and M&M Consulting 2021-04-0710 min

The Compliance 911 ShowNational Defense Act impacts on BSA/AMLThis podcast Dean will address key provisions under NDAA that will impact BSA/AML, so everyone is prepared. Brought to you by GeoDataVision and M&M Consulting 2021-03-2409 min

The Compliance 911 ShowThe Pandemic and CRAIn this podcast nationally recognized CRA expert Len Suzio explains the various ways in which the Covid-19 Pandemic affects a bank's CRA responsibilities. Do you know how PPP loans affect your CRA performance? Do you know how the Disaster Declaration impacts Community Development activities? Tune in to listen to Len Suzio give detailed answers to these questions. Brought to you by GeoDataVision and M&M Consulting 2021-03-0108 min

The Compliance 911 ShowCompliance Management Systems and COVIDThis podcast highlights key areas of concern on CMS as a result of the pandemic. Areas impacted include BSA, Fair Lending, Consumer Regulations. Brought to you by GeoDataVision and M&M Consulting 2021-02-1908 min

The Compliance 911 ShowMajor changes contained in the Federal Reserve Board's Advanced Notice of Proposed Rule-Making regarding the Community Reinvestment Act.This podcast discusses the major changes contained in the Federal Reserve Board's Advanced Notice of Proposed Rule-Making regarding the Community Reinvestment Act. The content of this podcast is time-sensitive. The ANPR was published in October 2020 and comments are due no later than February 16, 2021. It is expected that all 3 federal bank regulators will eventually join in a final rule-making based on the Fed's ANPR. Brought to you by GeoDataVision and M&M Consulting To comment at FRB for CRA ANPR simply go to https://www.federalreserve.gov/secure/forms/ElectronicCommentForm.aspx?doc_id=R%2D1723&doc_ve...2021-02-0607 min