Blog

On April 3, 2018 the U.S. Department of the Treasury released recommendations to modernize the Community Reinvestment Act (CRA). The recommendations were issued to the primary CRA regulators, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation.  Treasury’s objective in developing these recommendations is to better align CRA activity with the needs of the communities that banks serve, while being conducted in a manner consistent with

The wait is finally over as FinCEN released Frequently Asked Questions to the CDD requirements published on May 11, 2016.  In the nearly two years since being published, we have also seen amendments to the requirements on September 29, 2017 ahead of the May 11, 2018 mandatory compliance date. The 24-page document includes 37 questions ranging from thresholds; identification and verification steps; collection and retention of beneficial ownership information; as well as exclusions and CTR

On March 20, 2018 the FDIC board of directors approved a final rule to raise the appraisal thresholds for commercial real estate transactions from $250,000 to $500,000. The threshold for loans secured by one-to-four family residential properties will remain at $250,000. The final rule increases the commercial real estate appraisal threshold with three modifications from the proposal. First, the agencies have increased the commercial real estate appraisal threshold to $500,000 rather than $400,000 as proposed.

On March 20, 2018 the Consumer financial Protection bureau (CFPB) updated the Mortgage Servicing FAQs. The updated FAQs pertain to compliance with Regulation X and Regulation Z, effective April 19, 2018. The updates deal primarily with recent revisions to Regulation that are effective on April 19, 2018. Read More: A copy of the FAQs is available at:  https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/cfpb_mortgage-servicing_frequently-asked-questions.pdf More information about the recent changes to Regulation Z are available at:  https://mycomplianceresource.com/last-minute-revisions-to-regulation-z-servicing-rules/  

On March 6, the House of Representatives took action on several banking related bills. As typical the bills next go to the Senate. The Portfolio Lending and Mortgage Access Act (H.R. 2226) passed by voice vote. It would provide a “qualified mortgage” safe harbor for all loans held in portfolio for institutions under $10 billion in assets. The Comprehensive Regulatory Review Act (H.R. 4607) passed by a vote of 264 to 163. It would ensure