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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

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

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

The Bureau of Consumer Financial Protection has released the Filing Instructions Guide, or FIG, for Home Mortgage Disclosure Act (HMDA) data collected in 2019 and reported in 2020. There are no significant changes to the submission process for data collected in 2019 and reported in 2020 and, therefore, no significant changes to the FIG. However, updates were made and financial institutions will need to be aware of the changes to the FIG for data collected in 2019. A

On October 23, the Bureau of Consumer Financial Protection (the Bureau) released its Complaint Snapshot: 50 State Report. According to the Bureau, the report “…provides a high-level overview of trends in consumer complaints and supplements the Consumer Response Annual Report with more recent information on complaints about consumer financial products and services by state.” From July 2011, when the Bureau began receiving complaints, through June 30, 2018, the Bureau had received approximately 1,578,700 complaints. The