2023 HMDA GUIDE
Category: FDIC, Federal Reserve Board, FFIEC, HMDA, NCUA, OCC, Regulation C
The federal bank regulatory agencies are announcing the Federal Financial Institutions Examination Council’s (FFIEC) revised “A Guide to HMDA Reporting: Getting It Right!” (2023 guide). The 2023 guide provides resources to help banks1 comply with the Home Mortgage Disclosure Act (HMDA) and Regulation C, its implementing regulation (12 CFR 1003). The 2023 guide reflects a technical amendment to the 2020 HMDA rule to adjust the loan volume thresholds effective January 1, 2023,2 for reporting HMDA data on
The final rule implementing Section 1071 of the Dodd-Frank Act is massive. There are a couple additional pieces of guidance that may offer relief to some institutions. The Consumer Financial Protection Bureau (CFPB) has provided a Filing Instructions Guide, a Small Business Lending rule: Data Points Chart, a Grace Period Policy Statement and a Statement on Enforcement and Supervisory Practices Relating to Small Business Lending Rule. Details follow. Filing Instructions Guide – The 2024 Filing
The proposed regulation to implement section 1071 did not address the handling of joint applications. This writer and others commented on the lack of guidance for reporting joint applications. Joint applications for commercial and agricultural loans are not common, but they do occur. The issue is whether information is collected for each applicant, or for a single applicant, and if a single applicant, which applicant. The final regulation, published on March 30, includes comment 103(a)-10
Today the Consumer Financial Protection Bureau (CFPB) finalized the Section 1071, Business Data Collection rule required by Congress to increase transparency in small business lending, promote economic development, and combat unlawful discrimination. The rules require Lenders to collect and report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit. The CFPB stated “the rule will work in concert with the Community Reinvestment Act,
CFPB’s Releases a Special Supervisory Highlights Report All About Junk Fees
Category: CFPB, Compliance Management, Fair Banking, Fair Lending, Fees, Junk Fees, Overdrafts, Risk Retention, UDAAP
Fee practices continue to be in the spotlight and with the release of the special addition of the CFPB’s Supervisory Highlight, it looks like they are about to get even more attention and scrutiny. The Highlights come within a few months of major enforcement actions and other CFPB guidance. Since the fall of 2022, three financial institutions have had the unfortunate experience of being cited and accused of having potentially unfair, deceptive, or abusive policies
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