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REVISED REGULATION Z EXAMINATION PROCEDURES

On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had […]

STERN REMINDER OF THE END OF LIBOR

On October 5, 2021, Federal Reserve Board Vice Chair for Supervision Randal K. Quarles spoke at The Structured Finance Association Conference in Las Vegas on “Goodbye to All That: The End of LIBOR.” Quarles reminded his audience that while LIBOR will no longer be a functional index after June 30, 2023, it will not be available for use in any new contracts after the end of 2021 — just 85 days from today. The Federal Reserve and […]

COMMUNITY BANK GUIDE – FINTECH DUE DILIGENCE

On August 27, 2021, the Federal Reserve, FDIC, and OCC released a 20-page guide intended to help community banks assess risks when considering relationships with financial technology (fintech) companies. Community banks are entering into business arrangements with fintech companies to offer enhanced products and services to their customers, increase efficiency, and reduce internal costs. The guide is intended to serve as a resource for community banks when performing due diligence on prospective relationships with fintech […]

JOINT AGENCY EFFORT TO IMPROVE CRA

On July 20, 2021, the Federal Reserve Board (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) jointly announced the agencies are committed to working together to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA). The OCC separately announced it will propose rescinding the CRA final rule issued in May 2020 and is committed to working with the Board and the FDIC to put forward […]

PROPOSED INTERAGENCY GUIDANCE ON THIRD-PARTY RELATIONSHIPS

On July 15, 2021, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued an interagency proposed rule on managing risks associated with third-party relationships. The proposed guidance would: Offer a framework based on sound risk management principles for banking organizations to consider in developing risk management practices for all stages in the life cycle of third-party relationships […]