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Final Final Fair Debt Collections Practices Act is Published

Posted by jholzknecht on  December 19, 2020
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On December 18, 2020, the Consumer Financial Protection Bureau (CFPB) released the second part of its final rule, Regulation F, which implements the Fair Debt Collection Practices Act. The first part of the final rule was published on October 30, 2020. The most recent release has three primary components dealing with validation notices, passive debt collection through negative reporting, and the collection of time-barred debt.  Most notably, the provisions dealing with time-barred debt depart significantly

CRA Asset-Size Threshold

Posted by jholzknecht on  December 18, 2020
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On December 17, 2020 the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation announced the annual adjustment to the asset-size thresholds used to define small bank and intermediate small bank under the Community Reinvestment Act (CRA) regulations. At this time the Office of the Comptroller of the Currency has not released its updated CRA threshold.Annual adjustments to these asset-size thresholds are based on the change in the average of

TEMPORARY ASSET THRESHOLDS

Posted by jholzknecht on  December 12, 2020
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On December 2, 2020 the Office of the Comptroller of the Currency, the Federal Reserve Board of Governors, and the Federal Deposit Insurance Corporation (collectively the Agencies) published an interim final regulation (IFR) to mitigate temporary transition costs on banking organizations related to the coronavirus disease 2019 (COVID event), by issuing an interim final rule to permit national banks, savings associations, state banks, bank holding companies, savings and loan holding companies, and U.S. branches and

CFPB ISSUES TWO QM RULES

Posted by jholzknecht on  December 11, 2020
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On December 10, 2020, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Rule, replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43 percent with a limit based on the loan’s pricing. The second final rule, reveals a new Seasoned QM.General QM – Under the final rule a loan receives a conclusive presumption

INTERAGENCY STATEMENT – CEASE ORIGINATION OF LIBOR-BASED CONTRACTS

Posted by jholzknecht on  December 1, 2020
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On November 30, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a statement to encourage banks to cease entering into new contracts that use USD LIBOR as a reference rate as soon as practicable and in any event by December 31, 2021, in order to facilitate an orderly—and safe and sound— LIBOR transition.
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