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CFPB SHIFTS ITS MISSION

Posted by jholzknecht on  December 29, 2017
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Category: CFPB
One of the two Acting Directors of the Consumer Financial Protection Bureau (CFPB) is quietly putting his stamp on the agency. Mr. Mulvaney is changing small details like the tag line that appears on CFPB press releases. Before Mr. Mulvaney showed up the tag line read, “The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and

FINAL 2018 LENDING THRESHOLDS

Posted by jholzknecht on  December 27, 2017
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Each year more than a half dozen lending thresholds are published by the federal regulators from mid-summer to the last days of the year.. The thresholds determine coverage for various requirements in the Home Mortgage Disclosure Act, the Truth in Lending Act and the Community Reinvestment Act. On December 27, 2017 the Consumer Financial Protection Bureau (CFPB) published the final lending thresholds for 2017. The HMDA asset-size exemption threshold was increased from $44 million to

LATE YEAR SERVICEMEMBER REVISIONS

Posted by jholzknecht on  December 26, 2017
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Laws that impact lending to servicemembers include the Military Lending Act and the Servicemembers Civil Relief Act. Both laws have been recently amended. Both sets of amendments bring clarity to areas of uncertainty. In response to these recent changes all creditors need to update their compliance management systems. Changes to policies, procedures, audit and training are needed to assure continued compliance. The revisions are already effective. Servicemembers Civil Relief Act (SCRA) On December 12, 2017

CFPB ANNOUNCES HMDA FORBEARANCE

Posted by jholzknecht on  December 22, 2017
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Category: CFPB, HMDA, Regulation C
On December 21, 2017 the Consumer Financial Protection Bureau (CFPB) issued a public statement announcing that the CFPB: Does not intend to require data resubmission unless data errors are material or assess penalties with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA). Intends to open a rulemaking to reconsider various aspects of the CFPB’s 2015 HMDA rule, such as the institutional and transactional coverage

2018 CRA THRESHOLDS PUBLISHED

Posted by jholzknecht on  December 21, 2017
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On December 21, 2017 the Federal Deposit Insurance Corporation, Federal Reserve Board of Governors, and the Office of the Comptroller of the Currency, together referred to as the Agencies, published the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. Annual adjustments to these asset-size thresholds are based on the change in the average of
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