Blog

2018 was an interesting year for those of us in the compliance field. We completed implementation of HMDA and TRID revisions, and got a jump start on implementing the provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). In last year’s New Years greeting I stated, “In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have

On December 31, 2018, with the last few hours of 2018 quickly approaching, the Consumer Financial Protection Bureau has published the final lending threshold updates just in time for 2019. The updates include: The HMDA asset-size exemption threshold, increased from $45 million to $46 million. The final rule is available here. The Truth in Lending asset-size exemption for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a

Fortunately the Federal Emergency Management Agency (FEMA), with some arm-twisting from the mortgage lending industry and Congress, has backed off on its position of not allowing the operations of the National Flood Insurance Program (NFIP) to resume during the government shut down. The change is retroactive to December 21, 2018, the date Congress provided last minute funding for the NFIP. With the NFIP funding crisis resolved until May 31, 2019, hopefully Congress can shift their

We reported on December 23rd that the President had signed legislation extending the National Flood Insurance Program (NFIP) until May 31, 2019. The Congress and the President did their part,  but then the Federal Emergency Management Agency (FEMA) ruled on December 27th that the NFIP cannot be renewed during the ongoing government shutdown. Now the industry is protesting FEMA’s ruling, saying that it conflicts with the will of Congress expressed in the bill signed into

On December 20, 2018 the Federal Deposit Insurance Corporation, Federal Reserve Board of Governors, and the Office of the Comptroller of the Currency, together referred to as the Agencies, published the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. Annual adjustments to these asset-size thresholds are based on the change in the average of