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On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the

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

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