Archive

OCC ISSUES CMP INFLATION ADJUSTMENTS FOR NATIONAL BANKS AND FEDERAL SAVINGS ASSOCIATIONS

The Office of the Comptroller of the Currency (OCC) has published a final rule announcing changes to the maximum amount of each civil money penalty (CMP), for national banks and Federal savings associations, to account for inflation pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990 as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The adjustments serve to maintain the deterrent effect of civil penalties and to […]

CFPB Advisory Opinion on Special Purpose Credit Program

On December 21, 2020, the Consumer Financial Protection Bureau published an Advisory Opinion (AO) on Special Purpose Credit Programs established per the requirements of the Equal Credit Opportunity Act and Regulation B. It is designed to address regulatory uncertainty in special purpose credit programs designed and implemented by for-profit organizations to meet special social needs. Specifically, this AO clarifies: The content that a for-profit organization must include in a written plan that establishes and administers […]

HPML ESCROW EXEMPTION THRESHOLD INCREASED FOR 2021

For 2021, the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan (HPML). The exemption threshold is adjusted to increase to $2.230 billion from $2.202 billion. Creditors with assets of less than $2.230 billion (including assets of certain affiliates) […]

2021 HOME MORTGAGE DISCLOSURE ACT THRESHOLD INCREASE

On December 22, 2020 the Consumer Financial Protection Bureau published a final rule amending the official commentary that interprets the requirements of Regulation C (Home Mortgage Disclosure Act) to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). For 2021, the exemption threshold is increased to $48 million from $47 […]