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On June 5, 2020, the Office of the Comptroller of the Currency (OCC) published a final rule revising its Community Reinvestment Act (CRA) regulation. The revised rule, which applies to national banks, federal savings associations, and federal branches of foreign banking organizations that are subject to the OCC’s regulations under CRA, was effective on October 1, 2020. Since June, the industry has been waiting for additional information essential for implementing the final rule. On January

On January 20, President Biden’s Chief of Staff Ronald Klain issued memorandum to the heads of executive departments and agencies setting forth the terms of a regulatory freeze. Summary The memorandum requires the following subject to limited exceptions: No rules can be issued or proposed until a department or agency head appointed by President Biden has reviewed and approved the rule.A rule that has been sent to the Federal Register but not yet published must be immediately withdrawn

On January 13, 2021, the Illinois legislature passed SB 1792, that, among other things, overhauls the state’s consumer finance laws through the provisions of the “Predatory Loan Prevention Ac.t” SB 1792 would extend the 36% “all-in” Military Annual Percentage Rate (MAPR) finance charge cap of the federal Military Lending Act (MLA) to “any person or entity that offers or makes a loan to a consumer in Illinois” unless made by a statutorily exempt entity (i.e.,

On January 19. 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending section 1026.35 of Regulation Z to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The rule will take effect on publication in the Federal Register. It exempts from the HPML escrow

On January 14, 2021, Brian Brooks, Comptroller of the Currency, issued a final rule establishing standards that a bank must follow in fulfilling its obligation to provide fair access to financial services.  The final rule is effective on April 1, 2021. The final rule applies to banks with $100 billion or more in total assets. The OCC interprets “fair access to financial services” to recognize its broad responsibility to ensure that banks make decisions about