On May 18, 2021, the Office of the Comptroller of the Currency (OCC) published OCC Bulletin 2021-2, which states that the OCC has determined that it will reconsider the final CRA Rule published on June 5, 2020. While this reconsideration is ongoing, the OCC: Will not object to the suspension of the development of systems for, or other implementation of, provisions with a compliance date of January 1, 2023, or January 1, 2024, under the […]
Month: May 2021
FRB EXTENDS REGULATION O PPP EXCEPTION
On May 14, 2021, the Federal Reserve Board announced the third extension of a temporary modification to Regulation O that allows certain bank directors and shareholders to apply to their banks for PPP loans for their small businesses. The rule extension, which is effective immediately, applies to PPP loans made from March 31 through June 30, 2021. The rule change will continue to apply if the PPP is extended, with the change ultimately sunsetting on March […]
FIVE TRID FAQS ADDED
The Consumer Financial Protection Bureau has added five new questions and answers related to Housing Assistance Loans to the TILA-RESPA Integrated Disclosure FAQs. The new questions, which are effective immediately, cover: Are housing assistance loans covered by the TRID rule? What are the criteria for the Regulation Z Partial exemption from the Loan Estimate and Closing Disclosure Requirements? What are the criteria for the BUILD Act Partial Exemption from the Loan Estimate and Closing Disclosure […]
SPECULATION ENDS – FDCPA AND UDAP CROSS PATHS
Massive revisions to the Fair Debt Collection Practices Act (FDCPA), and its implementing Regulation F, have been unfolding over the past few years. The final rule is effective on November 30, 2021, although the CFPB has proposed to extend the effective date to January 29, 2022. Many banks want to operate under the assumption that the FDCPA and Regulation F do not apply to their operations. We have steadfastly maintained that the law and regulation […]