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On May 11, 2018, the effective date of the Beneficial Ownership requirements, the Federal Financial Institutions Examination Council (FFIEC) issued new examination procedures on the final rule, “Customer Due Diligence Requirements for Financial Institutions,” issued by the Financial Crimes Enforcement Network (FinCEN) on May 11, 2016. The examination procedures apply to banks, savings and loan associations, savings associations, credit unions, and branches, agencies, and representative offices of foreign banks. The new examination procedures replace those

On May 10, 2018 the Consumer Financial Protection Bureau (CFPB) published its semi-annual regulatory agenda. The agenda includes rulemaking actions in pre-rule, proposed rule, final rule, long-term, inactive, and completed stages. Priorities are clearly changing. The agency’s Acting Director has decided to reclassify as “inactive” certain rulemakings that had been listed in previous editions of the agenda in the expectation that final decisions on whether and when to proceed with such projects will be made

On April 28, 2018 the Consumer Financial Protection Bureau (CFPB) finalized an amendment to its Truth in Lending/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) that addresses when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith. Under the current rule, circumstances may arise in which a cost

On April 19, 2018 the Federal Reserve Board published a Consumer Affairs Letter (CA 18-3) regarding Revised Interagency Examination Procedures for Regulation X and Regulation Z. The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently developed the interagency examination procedures for the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA). The revised examination procedures supersede the examination procedures transmitted with CA Letter 15-6. The procedures

On April 9, 2018 the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); and Federal Deposit Insurance Corporation (FDIC) published a final rule to amend the agencies’ regulations requiring appraisals of real estate for certain transactions. The final rule increases the threshold level at or below which appraisals are not required for commercial real estate transactions from $250,000 to $500,000 and makes other changes. The final