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HPML ESCROW EXEMPTION THRESHOLD INCREASED FOR 2021

Posted by rcooper on  December 22, 2020
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Category: Uncategorized
For 2021, the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan (HPML). The exemption threshold is adjusted to increase to $2.230 billion from $2.202 billion. Creditors with assets of less than $2.230 billion (including assets of certain affiliates)

2021 HOME MORTGAGE DISCLOSURE ACT THRESHOLD INCREASE

Posted by rcooper on  December 22, 2020
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Category: Uncategorized
On December 22, 2020 the Consumer Financial Protection Bureau published a final rule amending the official commentary that interprets the requirements of Regulation C (Home Mortgage Disclosure Act) to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). For 2021, the exemption threshold is increased to $48 million from $47

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

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
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