Posted by jholzknecht on  January 1, 2020

Category: Uncategorized
To all of the dedicated compliance professionals that we have the privilege to work with throughout the year, we wish you a healthy, prosperous, and fulfilling new year. Jack Holzknecht Amy Faust Robin Cooper Brent Vincent
On December 20, 2019 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 2020 the exemption is increased to $47 million from $46 million.


Posted by jholzknecht on  December 30, 2019

On December 30, 2019 the OCC, the Board, and the FDIC (collectively the Agencies) amended their Community Reinvestment Act (CRA) regulations to adjust the asset-size thresholds used to define ” small bank” or “small savings association” and “intermediate small bank” or “intermediate small savings association.” As required by the CRA regulations, the adjustment to the threshold amount is based on the annual percentage change to the Consumer Price Index for Urban Wage Earners and Clerical
For 2020 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.  The exemption threshold is adjusted to $2.202 billion from $2.167 billion.  The revised commentary to regulation Z, Paragraph 1026.35(b)(2)(iii)-1(iii)(E), includes the amended threshold stating: Under section 1026.35(b)(2)(iii)(C),


Posted by Brent V on  December 26, 2019

Category: Lending Compliance
On July 1, 2019, the Taxpayer First Act of 2019 was signed into law.  The legislation expands taxpayer rights and reforms the Internal Revenue Service (IRS) into a more consumer friendly agency through focus on customer service, technology and enhancing cyber security. Effective December 28, 2019, Section 2202 of the Act, amends IRS law 26 USC 6103(c) to include the following language: “Persons designated by the taxpayer under this subsection to receive return information shall

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