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CRA – ADVANCED NOTICE OF PROPOSED RULEMAKING

Posted by jholzknecht on  August 28, 2018
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Category: CRA, OCC
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On August 28, 2018 the Office of the Comptroller of the Currency released an Advanced Notice of Proposed Rulemaking (ANPR) seeking comment on the best ways to modernize the regulatory framework implementing the Community Reinvestment Act (CRA). The ANPR solicits comment on a number of questions related to increasing lending and services to people and in areas that need it most, including in LMI areas; clarifying and expanding the types of activities eligible for CRA

REGULATION Z – SELECTED 2019 THRESHOLDS

Posted by jholzknecht on  August 27, 2018
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On August 27, 2018 the Consumer financial Protection Bureau (CFPB published a final rule amending Regulation Z. The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule revises, as applicable, the dollar amounts for provisions implementing TILA and amendments to TILA, including under: The Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act); The Home Ownership and Equity Protection Act of 1994 (HOEPA); and

EXTENDED EXAMINATION CYCLE

Posted by jholzknecht on  August 24, 2018
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On August 23, 2018 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) issued interim final rules to allow qualifying insured depository institutions (generally those that are well capitalized and well managed) with less than $3 billion in total assets to benefit from an extended 18-month on-site examination cycle (up from the previous 12-month cycle). Prior to enactment of the

OCC TWEAKS CRA RATING POLICY

Posted by jholzknecht on  August 17, 2018
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Category: CRA, OCC
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On August 15, 2018 the Office of the Comptroller of the Currency (OCC) published OCC Bulletin 2018-23 to make public the revised Policies and Procedures Manual (PPM) 5000-43, which clarifies the OCC’s policy for applying the regulatory framework to determine the effect of evidence of discriminatory or other illegal credit practices on the Community Reinvestment Act (CRA) rating of a national bank, federal savings association, or federal branch. The updated PPM replaces and rescinds OCC PPM 5000-43,

PRIVACY PROVISIONS FINALLY FINALIZED

Posted by jholzknecht on  August 13, 2018
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Category: CFPB, Privacy, Regulation P
On August 10, 2018 the Bureau of Consumer Financial Protection (CFPB) completed the nearly three year process of issuing relatively minor amendments to implement legislation that allows financial institutions that meet certain requirements to be exempt from sending annual privacy notices to their customers. The Gramm-Leach-Bliley Act (GLBA) generally requires that financial institutions send annual privacy notices to customers. In December 2015, Congress amended the GLBA as part of the Fixing America’s Surface Transportation Act
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