Archive

INTERAGENCY STATEMENT ON LIBOR TRANSITION

On November 6, 2020, the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a Statement on Reference Rates for Loans. The statement reiterates that the agencies are not endorsing a specific replacement rate for LIBOR for loans. A bank may use any reference rate for its loans that the bank determines to be appropriate for its funding model and customer needs. However, the bank should […]

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FRB ISSUES ANPR FOR CRA

On September 21, 2020, the Federal Reserve Board of Governors (FRB) released an Advanced Notice of Proposed Rulemaking (ANPR) that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks. The ANPR has a 120-day comment period that begins once the ANPR is published in the Federal Register. The FRB’s ANPR stands in contrast to the final CRA regulations published by the Office of the Comptroller […]

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ARE REGULATORS RENEGING ON CRA PROMISES?

On March 19, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) published a Joint Statement of Policy (SOP) promising favorable consideration of retail banking services and retail lending activities in a financial institution’s assessment areas that are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected […]

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INTERAGENCY FLOOD FAQS

On June 26, 2020 the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively the Agencies) released proposed new and revised Interagency Questions and Answers Regarding Flood Insurance (FAQs). The FAQs have not been updated since 2011, which is gross incompetence on the part of the Agencies. Since the last revisions Congress has passed the Biggert-Waters Act and the Affordability Act, […]

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INTERAGENCY LENDING PRINCIPLES FOR OFFERING RESPONSIBLE SMALL-DOLLAR LOANS

On May 20, 2020 the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the National Credit Union Administration jointly issued the Interagency Lending Principles for Offering Responsible Small-Dollar Loans. The agencies: Recognize the important role that responsibly offered small-dollar loans can play in helping customers meet their ongoing needs for credit from temporary cash-flow imbalances, unexpected expenses, or income shortfalls, including during periods of economic stress, […]

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