Can we see the light at the end of the tunnel? Maybe faintly. Truth-in-Lending/RESPA Integrated Disclosures (TRID) – The biggest pending issue is the TRID rules that are effective August 1, 2015. Some vendors have delivered updates to loan origination software for testing. Policies, procedures, and training need to be completed. But it is appears likely that most lending institutions will complete all required tasks by the deadline. Some, like the banker I talked to […]
Category: Federal Reserve Board
FINAL RISK RETENTION RULES
On October 22, 2014 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 jointly issued a final rule to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934 (15. U.S.C. 78o-11), as added by section 941 of […]
PROPOSED FLOOD INSURANCE REGULATIONS
The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) (collectively, the Agencies) are proposing to amend their flood insurance regulations to implement certain provisions of the Homeowner Flood Insurance Affordability Act of 2014 (HFIAA), which amends some of the changes to the Flood Disaster Protection Act of 1973 mandated […]
INTERAGENCY GUIDANCE ON HELOCS NEARING THEIR END-OF-DRAW PERIODS
On July 1, 2014 the federal financial institution regulatory agencies published guidance regarding the risk associated with Home Equity Lines of Credit (HELOCs) transitioning from their draw periods to full repayment. This is not a new issue. HELOCs have been part of product mix for financial institutions since the 1980s. Most HELOCs have a five or ten year draw period. During the draw period, a borrower has revolving access to unused amounts under a specified […]
PROPOSED REPEAL OF REGULATION AA
On August 22, 2014 the Federal Reserve Board requested comment on a proposal to repeal its Regulation AA (Unfair or Deceptive Acts or Practices). Also on Friday, the Board, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency issued guidance clarifying that the repeal of the credit practices rules applicable to banks, savings associations, and federal credit unions is not a determination that the […]