On November 7th, the FFIEC finalized the issuance of its updated Interagency Consumer Compliance Rating System (“CCRS”). The press release that accompanied the revision stated that the document was intended to “more fully align the rating system with the FFIEC agencies current risk-focused, tailored examination approaches” and that “the rating system’s adoption will represent no additional regulatory burden for financial institutions”. Or does it? So, far so good as we’ve all long known, through various […]
Category: FFIEC
CFPB STANDS IN WAY OF SOLUTION TO HMDA REPORTING PROBLEM
Collection of 2017 HMDA data begins in less than two months. The Consumer Financial Protection Bureau announced last summer in its 2017 Filing Instructions Guide (FIG) that beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the Consumer Financial Protection Bureau (CFPB) using a web interface referred to as the HMDA Platform. The HMDA Platform has not been released. That puts the industry in the awkward position of collecting 2017 […]
HMDA FIG PUBLISHED
The much anticipated Filing Instructions Guide (FIG) has been published by the Consumer Financial Protection Bureau (CFPB). Actually the CFPB has published two FIGs – one for data collected in 2017 and one for data collected in 2018 or later. The 2017 FIG is 47 pages in length. The 2018 Guide is 78 pages in length. Both are dated July 2016. The CFPB has also published a Technology Review and Frequently Asked Questions documents, […]
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 […]
2015 HMDA ISSUES
The January 2015 issue of the FFIEC’s CRA/HMDA Reporter has several good reminders about HMDA issues. The lead article, HOEPA Changes and New Edit Changes, focuses on changes to Regulation Z (HOEPA) rules that were effective in January 2014 and impacted the 2014 HMDA data just submitted by your bank. The changes lowered the rate spread threshold of HOEPA eligible loans, and expanded coverage to certain home purchase mortgage products. The Reporter is available by […]