On March 20, 2018 the FDIC board of directors approved a final rule to raise the appraisal thresholds for commercial real estate transactions from $250,000 to $500,000. The threshold for loans secured by one-to-four family residential properties will remain at $250,000. The final rule increases the commercial real estate appraisal threshold with three modifications from the proposal. First, the agencies have increased the commercial real estate appraisal threshold to $500,000 rather than $400,000 as proposed. […]


On March 20, 2018 the Consumer financial Protection bureau (CFPB) updated the Mortgage Servicing FAQs. The updated FAQs pertain to compliance with Regulation X and Regulation Z, effective April 19, 2018. The updates deal primarily with recent revisions to Regulation that are effective on April 19, 2018. Read More: A copy of the FAQs is available at: More information about the recent changes to Regulation Z are available at:  

Legislative Update

On March 6, the House of Representatives took action on several banking related bills. As typical the bills next go to the Senate. The Portfolio Lending and Mortgage Access Act (H.R. 2226) passed by voice vote. It would provide a “qualified mortgage” safe harbor for all loans held in portfolio for institutions under $10 billion in assets. The Comprehensive Regulatory Review Act (H.R. 4607) passed by a vote of 264 to 163. It would ensure […]


In an opinion filed on March 15, 2018 in the matter of Chamber of Commerce of the United States of America et al v. United States Department of Labor et al a majority of a three-member panel of the U.S. Court of Appeals for the Fifth Circuit (Louisiana, Mississippi, and Texas) has vacated the Department of Labor’s Fiduciary Rule . Three business groups had filed suits challenging the Fiduciary Rule finalized by the Department in April 2016. […]


On May 5, 2016 FinCEN issued its final rule on beneficial ownership and customer due diligence.  This rule was issued to strengthen customer due diligence requirements for covered institutions.  The rule included a new requirement to identify and verify the identities of beneficial owners of legal entity customers (LEC).  A beneficial owner was deemed as any individual who owns 25 percent or more of the equity interests of a LEC and a single individual with […]