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We have received several recent questions regarding flood insurance. Declaration Page – Are we still required to compare the risk rating on our flood determination to the risk rating on the flood insurance policy? FEMA has revised the declaration page for flood insurance policies. Among the changes, the risk rating has been removed. It is no longer possible to compare the risk rating from the Standard Flood Hazard Determination Form to the declaration page of

On October 25, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z and its Official Interpretations. The final rule revises the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The CFPB is

On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had

On October 26, the Office of the Comptroller of the Currency (OCC) took the unusual step of issuing frequently asked questions (Bulletin 2021-50) about a notice of proposed rulemaking (NPRM) soliciting comments on the proposal to rescind the OCC’s Community Reinvestment Act (CRA) rule issued on June 5, 2020. The NPRM, which was published in the Federal Register on September 17, 2021, proposes that the June 2020 CRA rule largely be replaced with the rules adopted jointly by the

On October 22, 2021 redlining hell broke loose. Trustmark – The Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ), in cooperation with the Office of the Comptroller of the Currency (OCC), took action today to put an end to alleged redlining by Trustmark National Bank. The CFPB and DOJ allege that Trustmark discriminated against Black and Hispanic neighborhoods by deliberately not marketing, offering, or originating home loans to consumers in majority-Black and