On May 18, 2016 the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), the Consumer Financial Protection Bureau (CFPB), the National Credit Union Administration (NCUA) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued guidance to ensure that financial institutions are aware of the Agencies’ supervisory expectations regarding deposit-reconciliation practices that may be detrimental to customers. Summary This guidance addresses a set of […]
Month: May 2016
CFPB SEMI-ANNUAL AGENDA
The CFPB recently released its spring 2016 semi-annual agenda. There are many repeat items listed in this agenda that were also present in the fall 2015 agenda (see Jack’s December 10, 2015 blog article). Those items repeated from the fall 2015 agenda appear to be either getting closer to final regulatory release or are being pushed further down the priority list. Some of the items mentioned in the agenda that we may see action on […]
LIABILITY AFTER FORECLOSURE – THE SEQUEL
Last fall, we published a blog article that reviewed the intricacies of the “Liability after Foreclosure” disclosure. Here we provide a quick update and add some valuable new information. As a refresher, the following disclosure appears in the Loan Estimate but only when the transaction is defined as a refinance: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses […]
MONUMENTAL DAY
May 10, 2016 is a monumental day for me. Forty years ago I began my banking career as an examiner for the FDIC. Every generation of bankers I have worked with says this new compliance stuff has taken the fun out of banking. Then that generation takes on the pile of new requirements, masters them, and makes them a part of the new daily routine. I had the privilege of working with some really great […]
SPECULATION ABOUT THE CFPB’S PENDING TRID PROPOSAL
As a result of a lot of pressure from many players in the mortgage lending game the CFPB has reluctantly agreed to publish proposed rules to clarify the massive pile of confusion that is called TRID. Recently CFPB Director Cordray sent a letter to the leadership and members of several industry trade groups reporting that the agency has begun drafting a Notice of Proposed Rulemaking on the TRID rules. Cordray stated the goal for publication […]