CRA – UPDATED THRESHOLDS FOR SMALL AND INTERMEDIATE-SMALL FINANCIAL INSTITUTIONS
Category: CRA, Lending Compliance
On December 21st the federal bank regulatory agencies announced 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. The annual adjustments are required by the CRA rules. The annual adjustments are based on the change in the average of the Consumer Price Index (CPI) for urban wage earners and clerical workers, not seasonally adjusted,
SAFE ACT UPDATE
Category: Lending Compliance, MLO Registration, SAFE Act
What’s the latest news on the SAFE Act? Expect to see a joint announcement before the end of the week that the National Registry will begin accepting MLO registrations on January 31, 2011. So what does this mean for you? You should already have your SAFE Act policy and procedures in place. They were required by October 1, 2010. If you haven’t yet identified which of your employees are MLOs you should do so between
The FACT Act’s Risk-Based Pricing Rules (Part 1 – The Big Picture)
Category: FACT Act, Lending Compliance, Risk-Based Pricing
Effective January 1, 2011 section 311 of the FACT Act requires a risk-based pricing notice. The notice is required when a person both: (1) Uses a consumer report in connection with an application for, or a grant, extension, or other provision of, credit to that consumer that is primarily for personal, family, or household purposes; and (2) Based in whole or in part on the consumer report, grants, extends, or otherwise provides credit to that
On Monday August 16th the Federal Reserve Board went crazy. They published a bunch of new and proposed regulations. These changes are huge and some of them are happening soon. A summary of each action is provided below. NEW PAYMENT INCREASE RISK DISCLOSURE The Fed issued an interim rule that revises the disclosure requirements for closed-end mortgage loans under Regulation Z (Truth in Lending). The interim rule implements provisions of the Mortgage Disclosure Improvement Act
The first of two final steps for implementation of the Secure and Fair Enforcement for Mortgage Licensing Act (the SAFE Act) has been completed. The final regulations are now in place; but we are still waiting for the Registry to open. FINAL REGULATIONS On July 28, 2010 the Comptroller of the Currency, Federal Reserve Board, Federal Deposit Insurance Corporation, Office of Thrift Supervision, Farm Credit Administration, and National Credit Union Administration (jointly referred to as
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