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
DISCOUNT POINTS
Category: Federal Reserve Board, Regulation Z, TRID, Truth in Lending
On November 28, the Federal Reserve Board (FRB) issued a consent order against Peoples Bank (Peoples), Lawrence, Kansas, for deceptive residential mortgage origination practices in violation of section 5 of the Federal Trade Commission Act. Apparently Peoples told certain borrowers that they were paying an additional amount for discount points that would lower the borrowers’ interest rate. In fact, many borrowers did not receive a reduced rate. The consent order requires Peoples to pay approximately
On December 14, 2017 the Department of Defense (DoD) published some much needed clarification on the Military Lending Act (MLA). Previous DoD interpretations, in the form of 19 Questions and Answers published during August 2016, provided less than sufficient answers to certain questions. The new guidance eliminates much of the confusion on those issues by amending its guidance on three of the questions and by providing one additional question and answer. Question 2 is amended
URLA – THE MOST RECENT OFFICIAL APPROVAL
Category: CFPB, ECOA, Regulation B, URLA
On November 20, 2017 the Consumer Financial Protection Bureau (CFPB) published its most recent Official Approval of the redesigned Uniform Residential Loan Application (URLA) to include an applicant language preference question. The first Official Approval of the URLA, which was issued by the CFPB on September 23, 2016: • Clarified that the relevant language in the redesigned URLA is in compliance with the regulatory provisions of Regulation B § 1002.5(b) through (d), regarding requests for
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