On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) published a notice of proposed rulemaking (NPRM) that creates a new category of Qualified Mortgage (QM), a seasoned QM (Seasoned QM), for first-lien, fixed-rate covered transactions that have met certain performance requirements over a 36-month seasoning period, are held in portfolio until the end of the seasoning period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements. The […]
Month: August 2020
AGENCIES UPDATE BSA/AML ENFORCEMENT STATEMENT
The Federal Reserve Board, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Association (Federal Banking Agencies or the Agencies), issued a Joint Statement on Enforcement of Bank Secrecy Act/Anti-Money Laundering Requirements (Statement) updating their 2007 Statement. The Agencies note this Statement does not create any new expectations or standards; rather, it clarifies how the Federal Banking Agencies evaluate enforcement actions when financial institutions fail to meet Bank Secrecy […]
ARE REGULATORS RENEGING ON CRA PROMISES?
On March 19, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) published a Joint Statement of Policy (SOP) promising favorable consideration of retail banking services and retail lending activities in a financial institution’s assessment areas that are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected […]
FINCEN PUBLISHES NEW CDD FAQS
On August 3, 2020, the Financial Crimes Enforcement Network (FinCEN) published three new Frequently Asked Questions (FAQs) regarding Customer Due Diligence (CDD) requirements for financial institutions. The new FAQs clarify the regulatory requirements related to: Obtaining customer information; Establishing a customer risk profile; and Performing ongoing monitoring of the customer relationship. The new FAQs are in addition to those that were published on: July 19, 2016; and April 3, 2018. For further information regarding customer […]
FFIEC STATEMENT ON ADDITIONAL LOAN ACCOMMODATIONS RELATED TO COVID-19
On August 3 the Federal Financial Institutions Examination Council (FFIEC) issued a statement setting forth prudent risk management and consumer protection principles for financial institutions to consider while working with borrowers as initial coronavirus-related loan accommodation periods come to an end and they consider additional accommodations. The COVID event has had a significant adverse impact on consumers, businesses, financial institutions, and the economy. To address some of these impacts, the Coronavirus Aid, Relief, and Economic Security […]