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
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
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
Category: CRA, FDIC, Federal Reserve Board, OCC
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
On November 3, 2017, the CFPB released the much anticipated HMDA Platform. The platform is the web portal that HMDA covered financial institutions must utilize to submit HMDA data beginning with its 2017 HMDA data. The platform has been available for testing since November 3rd; however, the CFPB sent out a reminder today regarding the official closing date of the platform. The beta testing period will officially close on December 31, 2017 to allow the
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