On November 23, 2018 federal banking agencies released two threshold adjustments for 2019, the Regulation Z and M exemption thresholds and the HPML appraisal threshold. Regulation Z and M Exemption Threshold: The Board of Governors of the Federal Reserve System (the Board) and the Bureau of Consumer Financial Protection (the Bureau) published final rules amending commentary and interpretations of their regulations which implement the Truth in Lending Act and Consumer Leasing Act, including the Bureau’s […]
Month: November 2018
AGENCIES PROPOSE AMENDMENTS TO REGULATIONS CC AND DD
On November 21, 2018 the Bureau of Consumer Financial Protection (the Bureau) and the Federal Reserve Board (FRB), collectively the Agencies, proposed amendments to Regulation CC, the implementing regulation for the Expedited Funds Availability (EFA) Act, that would allow for adjustments in amount of funds depository institutions must make available to customers. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the EFA Act giving joint rulemaking authority to the Bureau and […]
AGENCIES ISSUE PROPOSAL TO INCREASE RESIDENTIAL APPRAISAL THRESHOLD
On November 20, 2018, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the Agencies) released a proposed rule to amend the appraisal requirements. Specifically, the proposal would increase the threshold for which appraisals are required on residential real estate loans, define a residential real estate transaction, include an exemption for rural real estate transactions pursuant to the Economic Growth, Regulatory Relief and […]
TWO SMALL ENTITY COMPLIANCE GUIDES UPDATED FOR EGRRCPA
Last week the Bureau of Consumer financial Protection (BCFP) issued revised versions of the small entity compliance guides for the Loan Originator Rule and the Home Ownership and Equity Protection Act (HOEPA) Rule. Both Guides are updated for changes resulting from the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The Loan Originator Rule, among other requirements, addresses loan originator compensation, defines the concept of a loan originator and addresses qualification and other requirements related […]
REQUEST FOR INFORMATION ON SMALL DOLLAR LENDING
On November 14, 2018 the FDIC issued a nine-page request for information on small dollar lending, including steps that can be taken to encourage FDIC-supervised financial institutions to offer small-dollar credit products that are responsive to customers’ needs and that are underwritten and structured prudently and responsibly. The request was issued as FIL-71-2018. Comments will be accepted for 60 days following publication in the Federal Register, which is expected soon. The FDIC recognizes the important […]