Archive

AGENCY CRA MANEUVERS

There has been recent activity on the proposed Community Reinvestment Act (CRA) regulations, but it is not clear whether the process is moving in a positive direction or not. Brainard Explains FRB Position The Federal Reserve Board (FRB) decided not to join the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Company (FDIC) in issuing the proposed revisions to the CRA regulations. On January 8, 2020 FRB Governor Lael Brainard […]

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ARE YOU LIBOR READY?

Many financial institutions make consumer loans, residential mortgage loans, and commercial loans with pricing based on the London Inter-Bank Offered Rate (LIBOR). In 2017 the United Kingdom’s Financial Conduct Authority (the regulator that oversees the LIBOR panel) announced that, by the end of 2021, it will discontinue the index. The Federal Reserve Board of Governors and the Federal Reserve Bank of New York (FRBNY) in conjunction with the U.S. Treasury Department’s Office of Financial Research have […]

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REGULATORS UNABLE TO AGREE ON FUTURE OF CRA

Like kids in a sandbox the regulators cannot agree on the rules of the game being played. In this case the game is the Community Reinvestment Act. The implementing regulations and examinations procedures have been in serious need of revisions for 25 years. The agencies seem to agree that changes are needed, they just can’t agree on the direction of the change. Last year Comptroller of the Currency Otting jumped the gun and published an […]

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BOARD CONSIDERATION OF MUTUAL AID SOCIETY PLANS

The February 2019 revision to the flood insurance regulations provides a definition of a “mutual aid society” and describes the conditions under which a regulated lending institution may accept a flood protection plan issued by a mutual aid society. Within the Board’s Regulation H, 12 CFR 208.25(c)(3)(iv) enumerates those conditions. The first of the conditions for acceptability of a mutual aid plan requires that “the Board has determined that such plans qualify as flood insurance […]

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