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Conceptual image of a broken bridge symbolizing the CRA compliance and internal audit governance gap at financial institutions.
Consumer Compliance & Fair Lending
July 14, 2026

CRA Modernization Was Rescinded. The Audit Gap It Exposed Was Not.

Regulators abandoned the 2023 CRA modernization rule, but the preparation exposed longstanding governance, data, and oversight weaknesses that remain subject to examiner scrutiny. Institutions and their internal audit functions should revisit CRA now to confirm that two years of uncertainty did not create blind spots in an ongoing program.
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UDAAP compliance audit review for community and regional financial institutions facing state enforcement and private plaintiff risk.
Consumer Compliance & Fair Lending
July 10, 2026

The CFPB Stepped Back on UDAAP. State Regulators and Private Plaintiffs Did Not.

The federal footprint has narrowed. The enforcement surface has not. Institutions that repriced consumer products in 2024 and 2025 without refreshing their Unfair, Deceptive, and Abusive Acts or Practices (UDAAP) audit coverage are the ones whose next examination will find the gap.
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