Archive

HMDA FINAL RULE FOR EGRRCPA EXEMPTION

On August 31 the Bureau of Consumer Financial Protection issued a final rule to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule clarifies: That insured depository institutions and insured credit unions covered by a partial exemption under the EGRRCPA have the option of reporting exempt data fields as long as they report […]

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CRA – ADVANCED NOTICE OF PROPOSED RULEMAKING

On August 28, 2018 the Office of the Comptroller of the Currency released an Advanced Notice of Proposed Rulemaking (ANPR) seeking comment on the best ways to modernize the regulatory framework implementing the Community Reinvestment Act (CRA). The ANPR solicits comment on a number of questions related to increasing lending and services to people and in areas that need it most, including in LMI areas; clarifying and expanding the types of activities eligible for CRA […]

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REGULATION Z – SELECTED 2019 THRESHOLDS

On August 27, 2018 the Consumer financial Protection Bureau (CFPB published a final rule amending Regulation Z. The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule revises, as applicable, the dollar amounts for provisions implementing TILA and amendments to TILA, including under: The Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act); The Home Ownership and Equity Protection Act of 1994 (HOEPA); and […]

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EXTENDED EXAMINATION CYCLE

On August 23, 2018 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) issued interim final rules to allow qualifying insured depository institutions (generally those that are well capitalized and well managed) with less than $3 billion in total assets to benefit from an extended 18-month on-site examination cycle (up from the previous 12-month cycle). Prior to enactment of the […]

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OCC TWEAKS CRA RATING POLICY

On August 15, 2018 the Office of the Comptroller of the Currency (OCC) published OCC Bulletin 2018-23 to make public the revised Policies and Procedures Manual (PPM) 5000-43, which clarifies the OCC’s policy for applying the regulatory framework to determine the effect of evidence of discriminatory or other illegal credit practices on the Community Reinvestment Act (CRA) rating of a national bank, federal savings association, or federal branch. The updated PPM replaces and rescinds OCC PPM 5000-43, […]

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