Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]
Category: CFPB
CFPB RELEASES RURAL AND UNDERSERVED AREAS TOOL
This week the Consumer Financial Protection Bureau (CFPB) issued its Rural and Underserved Areas Tool linked here https://www.consumerfinance.gov/rural-or-underserved-tool/. The tool is designed to assist creditors in determining if properties are located in a rural or underserved area and eligible for certain exemptions from various requirements provided to certain small creditors under the CFPB’s mortgage rules. The Rural and Underserved Areas Tool is a the result of a final rule approved by the CFPB on September […]
CFPB SEMI-ANNUAL AGENDA
Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements […]
CFPB V LOS VENDORS – SHOT ACROSS THE BOW
In remarks at the recent Mortgage Bankers Association Convention Consumer Financial Protection Bureau Director Richard Cordray conceded that the implementation process for CFPB’s new “Know Before You Owe” mortgage disclosure rule (aka as TRID) has not been as smooth as the agency would have hoped. But Cordray faulted vendors, not regulators. “Quite frankly, I have been disturbed by reports I have been hearing about the vendors on whom so many of you rely,” he said. […]
REVISED HMDA RULES PUBLISHED
On October 15, 2015 the Consumer Financial Protection Bureau (CFPB) published revised Regulation C rules, which implement the Home Mortgage Disclosure Act. The revisions are effective for the most part on January 1, 2018, certain provisions are phased in through January 1, 2020. The revisions impact: Coverage – Coverage rules are slightly revised, but do not qualify as a major item on anyone’s list. The CFPB is playing this as meaningful reduction of regulatory burden. […]