Archive

ABA RCC – Day 1 – June 10

Orlando, FL The American Bankers Association (ABA) really knows how to throw a party. The 2012 American Bankers Association Regulatory Compliance Conference (RCC) is in Orlando. This is the 26th year the ABA has presented the conference Orlando is hot and humid this time of year, but when you sit in sessions from early morning until well into the evening the chill from the air conditioning is the bigger concern A beautiful hotel – The […]

REVISED INTERAGENCY FCRA EXAM PROCEDURES

On June 1, 2012 the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council released revised Interagency Examination Procedures for the Fair Credit Reporting Act. The revised examination procedures reflect recent amendments to the FCRA pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The Dodd-Frank Act revised sections 615(a) and 615(h) of the FCRA to require disclosure of credit scores and information relating to credit scores in: […]

FINALLY – REVISED STANDARD FLOOD HAZARD DETERMINATION FORM

The Standard Flood Hazard Determination Form (SFHDF) is used by Federally regulated lending institutions when making, increasing, extending, renewing or purchasing a loan for the purpose of determining whether flood insurance is required and available. The form is required by Section 303 (a) of Title V of the National Flood Insurance Reform Act of 1994 (NFIRA). The FEMA Form number for the Standard Flood Hazard Determination Form (SFHDF) has been changed from FEMA Form 81-93 […]

DODD-FRANK ACT – STATISTICAL UPDATE

Information recently released by Davis Polk shows: As of June 1, 2012, a total of 221 Dodd-Frank rulemaking requirement deadlines have passed. This is 55.5% of the 398 total rulemaking requirements, and 78.9% of the 280 rulemaking requirements with specified deadlines. Of these 221 passed deadlines, 148 (67.0%) have been missed and 73 (33.0%) have been met with finalized rules. Regulators have not yet released proposals for 21 of the 148 missed rules. Of the […]

THE FLOOD INSURANCE MERRY-GO-ROUND CONTINUES

On May 30th the President signed HR 5740, extending the NFIP’s authority for an additional 60 days. The law enables FEMA to enter into flood insurance contracts through July 31, 2012. For the past several years Congress has played this funding game. The flood laws need some serious attention. Congress cannot agree on the steps needed to improve the program. So rather than approve long-term funding for the insurance program a series of short-term funding […]