On August 23, 2018 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) issued interim final rules to allow qualifying insured depository institutions (generally those that are well capitalized and well managed) with less than $3 billion in total assets to benefit from an extended 18-month on-site examination cycle (up from the previous 12-month cycle). Prior to enactment of the […]
Category: Examination Procedures
TREASURY INDEX WEEKLY AND MONTHLY AVERAGES: WHERE DID THEY GO?
Many lenders use the Treasury Index, specifically the weekly and monthly averages, as an index for adjustable rate mortgages. The applicable index plus the internal margin set by the lender determines the interest rate that will be charged on an adjustable rate mortgage. Lenders have historically retrieved the Treasury Index weekly and monthly averages from the H.15 report (the Selected Interest Rates report published by the FRB). As of October 11, 2016, the Federal Reserve […]
REVISED REGULATION Z EXAMINATION PROCEDURES
Recently the federal financial institution regulatory agencies released updated Regulation Z Examination procedures. The revised interagency examination procedures reflect amendments implementing revisions to the Truth in Lending Act under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that: (1) restrict mandatory arbitration agreements in mortgage loans; and (2) revise existing escrow requirements on first-lien higher-priced mortgage loans. These amendments are effective with respect to transactions for which the creditor receives an application […]