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The February 2019 revision to the flood insurance regulations provides a definition of a “mutual aid society” and describes the conditions under which a regulated lending institution may accept a flood protection plan issued by a mutual aid society. Within the Board’s Regulation H, 12 CFR 208.25(c)(3)(iv) enumerates those conditions. The first of the conditions for acceptability of a mutual aid plan requires that “the Board has determined that such plans qualify as flood insurance

Recently the OCC, the FRB, the FDIC, the FCA, and the NCUA, through the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council, revised the Interagency Examination Procedures for the Flood Disaster Protection Act. The revised procedures reflect the February 2019 final interagency rule that addresses the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012. The updated procedures incorporate new sections that discuss: Mandatory acceptance of a

On August 19, 2019 the Department of Housing and Urban Development (HUD) proposed a rule to amend HUD’s interpretation of the Fair Housing Act’s disparate impact standard contained in HUD’s existing regulation 24 C.F.R. Part 100. The proposed rule makes it more difficult for a plaintiff to bring a disparate impact case and also  makes it more difficult for a plaintiff to recover punitive and exemplary damages. The proposed rule is good news for lenders

At the direction of the Federal Housing Finance Agency (FHFA), the Government Sponsored Enterprises (GSEs) will be making specific modifications to the Uniform Residential Loan Application (URLA) form. As a result, FHFA and the GSEs are postponing the February 1, 2020 mandatory compliance date of the URLA form and Automated Underwriting System (AUS) datasets to allow time for the industry to implement these modifications. A new effective date has not been set. In June, we

On August 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a final rule updating certain Regulation Z threshold amounts for 2020.  The adjusted thresholds affect amounts under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Qualified Mortgages). The adjusted amounts, effective January 1, 2020, include: The open-end consumer credit minimum