Archive

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, […]

Read More…

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, […]

Read More…

FLOOD INSURANCE COMPLIANCE IN RESPONSE TO THE CORONAVIRUS

On May 6, 2020 the Federal Reserve Board issued Consumer Affairs letter CA 20-7 on the topic of Flood Insurance Compliance in Response to the Coronavirus. On March 9, the Federal Reserve Board and the other federal financial institution regulatory agencies and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by the coronavirus.Since that time, the Federal Reserve Board […]

Read More…

AGENCIES DEFER APPRAISALS

On April 14, 2020 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation,  Office of the Comptroller of the Currency,  National Credit Union Administration,  and the Consumer Financial Protection Bureau (jointly, the agencies) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the interagency appraisal regulations. The agencies are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly […]

Read More…

REGULATION O MODIFIED FOR PPP LOANS

On April 17 the Federal Reserve Board published an interim final rule that excludes loans that are guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from many of the requirements of Regulation O. The rule is effective upon publication in the Federal Register, which is expected soon. The comment period expires 45 days after publication in the Federal Register. The final rule excludes from all requirements of Regulation O, except for the executive […]

Read More…