Recently the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); Federal Deposit Insurance Corporation (FDIC) published final revisions to the Interagency Questions and Answers Regarding Community Reinvestment. The final rule was based on a proposal issued on September 10, 2014 that addressed alternative systems for delivering retail banking services; community development-related issues; and the qualitative aspects of performance, including innovative or flexible lending practices and the […]
Category: Federal Reserve Board
2016 LIST OF DISTRESSED OR UNDERSERVED NONMETROPOLITAN MIDDLE-INCOME GEOGRAPHIES
On June 17, 2016 the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation announced the availability of the 2016 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration as community development. Distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies are designated by the agencies in accordance with […]
DEPOSIT RECONCILIATION PROCEDURES
On May 18, 2016 the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), the Consumer Financial Protection Bureau (CFPB), the National Credit Union Administration (NCUA) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) issued guidance to ensure that financial institutions are aware of the Agencies’ supervisory expectations regarding deposit-reconciliation practices that may be detrimental to customers. Summary This guidance addresses a set of […]
LOGIC BEHIND THE SMALL BANK FLOOD ESCROW EXEMPTION
We discussed the issue of the small bank exemption from the new flood insurance escrow requirements in previous articles entitled Flood Rule Conundrum and Flood Rule Conundrum – Part II. We almost called this one Flood Rule Conundrum – Part III, but we thought that would be too repetitious too repetitious. The issue is whether a small bank, that had previously escrowed for Higher-Priced Mortgage Loans (HPML), could be eligible for the new exemption from […]
JOINT AGENCIES ISSUE FINAL RULE ON FLOOD INSURANCE
The joint agencies (OCC, Federal Reserve Board, FDIC, Farm Credit Administration and NCUA) recently approved a final rule that modifies the regulation for loans secured by property located in a special flood hazard area. The final rule implements certain provisions that were established under the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA) such as the requirement to escrow for flood insurance premiums on residential improved real estate securing a loan, as well as, an […]