"We're seeing banks that have never been scrutinized before for redlining and being told that they have risk that they have not before and risk in ways that they've never really viewed it before," says Andrea Mitchell. "We're in some new territory, and I think it's important for CEOs to understand what their compliance officers and legal departments are seeing on the ground."

In the latest episode of the ABA Banking Journal Podcast — sponsored by Alkami — Andrea Mitchell, a top fair lending attorney, reviews the latest trends in redlining enforcement. She reviews cases brought by the Justice Department, the importance of screening programs, planning for entering new markets, the role of peer analyses in managing redlining risk and the effects of redlining enforcement on M&A activity.

Mitchell also discusses the intersection of DOJ enforcement and prudential supervision, noting that "if your regulator thinks you're doing very well, even in in terms of minority market lending, and is relying on your CRA rating, there's nothing that prevents HUD or DOJ or other agencies from scrutinizing you."