FRB Eliminates Six-Per-Month Regulation D Limit
Category: Coronavirus, Deposit Compliance, Regulation D
On Friday, April 24, 2020, the Federal Reserve Board announced an interim final rule amending Regulation D to immediately delete the six-per-month limit on convenient transfers from the definition of savings deposit and allow financial institutions to immediately to suspend enforcement of the six-transfer limit. Compliance Resource has been anticipating this amendment and is pleased to see this announcement, as this action brings relief to customers needing to easily access savings deposit funds during the
AGENCIES DEFER APPRAISALS
Category: Appraisals, CFPB, FDIC, Federal Reserve Board, NCUA, OCC
On April 14, 2020 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, National Credit Union Administration, and the Consumer Financial Protection Bureau (jointly, the agencies) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the interagency appraisal regulations. The agencies are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly
As of January 1, 2020 the threshold for reporting closed-end loans for purposes of HMDA was 25 loans. As announced last Friday, on July 1, 2020 the threshold increases to 100 closed-end loans. As a result, institutions that originate: Fewer than 25 closed-end loans continue to be exempt from reporting closed-end loans for HMDA; 25 or more, but fewer than 100, closed-end loans become exempt from reporting closed-end loans for HMDA effective July 1, 2020
On April 17 the Federal Reserve Board published an interim final rule that excludes loans that are guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from many of the requirements of Regulation O. The rule is effective upon publication in the Federal Register, which is expected soon. The comment period expires 45 days after publication in the Federal Register. The final rule excludes from all requirements of Regulation O, except for the executive
NEW HMDA REPORTING THRESHOLD
Category: CFPB, HMDA, Regulation C
On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about: Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of
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