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On October 17. 2016 the FDIC released revised interagency examination procedures that reflect the Department of Defense’s (DOD) 2015 amendments to the implementing regulations of the Military Lending Act of 2006 (MLA) and its August 2016 interpretive rule that provides guidance on certain questions received regarding compliance with the MLA rule. During early examinations, examiners will evaluate financial institutions’ compliance management systems and overall efforts to come into compliance. Specifically, examiners will consider an institution’s

On October 3, 2016 the CFPB issued its final rule for general purpose prepaid accounts which will generally go into effect on October 1, 2017.   This culminated a 4+ year wait since the CFPB announced its initial intention to regulate prepaid accounts and 2 years from its proposal.  The CFPB’s initial 870 page ANPR has morphed into a 1,689-page final rule so it’s easy to determine that numerous products and requirements were added on that

On September 23 the Consumer Financial Protection Bureau (CFPB) published an Official Approval concerning the new Uniform Residential Loan Application and the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race in 2017. The official approval was issued on September 23, 2016. Entities may rely on the official approval beginning January 1, 2017. The official approval is issued separately from, and without amending, the official interpretations to Regulation B contained in Supplement

In one week, on October 3, 2016, compliance with the revisions to Part 232, which implements the Military Lending Act (MLA), is mandatory. The revised rules were effective on October 1, 2015. but the revised provisions do not apply to credit consummated before October 3, 2016. For any covered transaction consummated on or after October 3, 2016 the creditor must provide required disclosures, assure the Military Annual Percentage Rate does not exceed 36%, and abide

The OCC entered into a Consent Decree with Business Bank of Texas on July 20, 2016 after the OCC initially announced its intentions to issue a Cease and Desist (C&D) Order. Previously, we issued a blog on the Beneficial Ownership FAQs (posted August 18, 2016) which stated that May 11, 2018 was the applicability date for the following requirements: Identification and Verification of Legal Entity Customers; and Requirement to add a new “fifth pillar”: Understand