Blog

On October 7, 2020, the Consumer Financial Protection Bureau published guidance in the form of fourteen Frequently Asked Questions (FAQs) on the Real Estate Settlement Procedures Act (RESPA) Section 8 topics. The FAQs provide an overview of the provisions of RESPA Section 8 and respective Regulation X sections, and address the application of certain provisions to common scenarios described in CFPB inquiries involving gifts and promotional activities, and marketing services agreements (MSAs). In addition, the CFPB determined

With the publication of OCC Bulletin 2020-86 the Office of the Comptroller of the Currency (OCC) released: A compliance guide for small banks; An initial illustrative list of qualifying activities; and A form to request consideration of items to be added to the list of qualifying activities. The OCC’s website includes these items and other information regarding the OCC’s new CRA regulation

In the early hours of October 1, 2020, the President signed H.R. 8337, which, among other provisions, extends the National Flood Insurance Program (NFIP) for a year until September 30, 2021. While the NFIP expired for an hour, the operations of the program were not disrupted.

On September 21, 2020, the Federal Reserve Board of Governors (FRB) released an Advanced Notice of Proposed Rulemaking (ANPR) that starts the process of revising the FRB’s Regulation BB, which implements the Community Reinvestment Act for state member banks. The ANPR has a 120-day comment period that begins once the ANPR is published in the Federal Register. The FRB’s ANPR stands in contrast to the final CRA regulations published by the Office of the Comptroller

On September 15, 2020, the Consumer Financial Protection Bureau (CFPB) announced the release of an Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 of the Dodd-Frank Act governing small business lending data collection and reporting. The Bureau will convene a Small Business Advocacy Review panel in October 2020. The panel will prepare a report that examines the impact of the potential rule on small businesses. Section 1071 requires financial institutions to collect