On Friday, March 13, 2020, the OCC issued OCC Bulletin 2020-15 and the FDIC issued FIL-17-2020 encouraging banks to take steps to meet the financial services needs of customers affected by Coronavirus (COVID-19) related issues. Both agencies provide information on steps banks can take to assist customers and communities, way the Agencies will help reduce burden on banks, and note all efforts must be consistent with safe and sound banking practices and applicable laws. Notable […]
Month: March 2020
CFPB EXPANDS HMDA FAQS
On March 6, 2020 the Consumer Financial Protection Bureau added a new question and answer to its Home Mortgage Disclosure Act FAQs. The new Question 7. appears under the heading Ethnicity, Race, and Sex and § 1003.4(a)(10)(i) Question: If a natural person applicant submits a mail, internet, or telephone application under Regulation C but does not provide race, ethnicity, or sex information, what should the financial institution report regarding whether this information was collected on […]
AGENCIES PUBLISH STATEMENT ON PANDEMIC PLANNING
The federal bank regulatory agencies have published an Interagency Statement of Pandemic Planning. The Federal Deposit Insurance Corporation (FDIC) released the statement with FIL-14-2020. The Office of the Comptroller of the Currency(OCC) released the statement with OCC Bulletin 2020-13. For further information on the topic see the recent Compliance Resource blog article on the topic
PANDEMIC PLANNING
As the government fully gears up for testing for the Coronavirus, the number of reported cases will likely explode. That is when the panic will begin and the need for your Coronavirus Business Continuity Plan will be the greatest. The Federal Bank Regulatory agencies have not provided any recent guidance related to an appropriate response to a pandemic. Previous guidance from the agencies on this topic includes: Influenza Pandemic Preparedness: Interagency Advisory, OCC Bulletin 2006-12, […]
MILITARY LENDING ACT INTERPRETIVE RULE REVISED
On February 28, 2020, the Department of Defense (DOD) published and made effective amendments to its interpretive rule related to the Military Lending Act (MLA). The MLA, which has undergone numerous revisions over the past several years, provides protection to servicemembers and their dependents by limiting the military annual percentage rate (MAPR) that a creditor may charge to a maximum of 36 percent and requiring disclosures among other consumer protections. Revisions to the MLA regulations […]