Archive

REGULATION E CIVIL MONETARY PENALTIES

Case 1 – In late July an Indiana bank was assessed a $70,000 penalty for engaging in unfair and deceptive acts or practices by the imposition of requirements on consumers in the resolution of electronic transfer errors which were more onerous than those set forth in Regulation E, thereby effectively delaying, denying or discouraging error resolution claims. Case 2 – In mid-July a bank located in Kentucky was assessed a $100,000 penalty for engaging in unfair […]

NEW RISK RETENTION (QRM) PROPOSAL

On August 28 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule the agencies issued in 2011 to implement […]

INTERAGENCY STATEMENT ON BIGGERT-WATERS FLOOD INSURANCE REFORM ACT

On April 1, 2013 the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the National Credit Union Administration, and the Farm Credit Administration (the Agencies) issued interagency guidance regarding the Flood Disaster Protection Act of 1973 (the FDPA), as amended by the Biggert-Waters Flood Insurance Reform Act of 2012 (the Act). The interagency guidance also provides information regarding the impact of the […]

PROPOSED REVISIONS TO INTERAGENCY CRA QUESTIONS AND ANSWERS

The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies) are proposing to clarify their Interagency Questions and Answers Regarding Community Reinvestment to address several community development issues. The Questions and Answers were first published under the auspices of the Federal Financial Institutions Examination Council (FFIEC) in 1996, and were last revised on March 11, 2010. The Agencies propose to: Revise five questions and answers, […]

INTERAGENCY APPRAISAL RULES FOR HIGHER-PRICED MORTGAGE LOANS

On January 16, 2013 the FDIC published an interagency rule to amend Regulation Z, as required by  the Dodd-Frank Act. The new rule established appraisal requirements for “higher-priced mortgages.” The other federal financial institution regulatory agencies are expected to join the effort on January 18th. The 305-page final rule is effective on January 18, 2014. The new rule prohibits a creditor from extending credit in the form of a higher-priced mortgage loan to any consumer […]