Both the Federal Reserve Board and the Federal Deposit Insurance Corporation published final rules repealing regulations that prohibited payment of interest on demand deposits, effective July 21, 2011. The Federal Reserve Board’s Regulation Q was repealed on July 12, 2011. The FDIC’s Part 329 was repealed on July 6, 2011. The regulations had been in place since 1933. The repeals were required by Section 627 of the Dodd-Frank Wall Street Reform and Consumer Protection Act […]
Category: Financial Reform
RULES AND ORDERS TO BE ENFORCED BY THE CFPB
On May 31st the Consumer Financial Protection Bureau (CFPB) published the list of the rules and orders it will enforce beginning on the designated transfer date of July 21, 2011. The list includes the agencies transferring rules and orders to the CFPB. The CFPB will be very busy in the coming months, and probably for several years to come. Board of Governors of the Federal Reserve 1. 12 CFR Part 202—Equal Credit Opportunity Act (Regulation […]
ABILITY TO REPAY – PROPOSED REGULATIONS
Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare […]
BUSINESS LOAN DATA COLLECTION
The one provision of the Dodd-Frank Act that strikes fear in the heart of bankers is the requirement to collect and report HMDA-like information on business loans. The provision is supposed to be effective on July 21, 2011. But since we don’t even have proposed regulations yet, we have suspected for some time now that the provision will be delayed. Leonard Kennedy, the recently appointed General Counsel of the Consumer Financial Protection Bureau, has made […]
THE YEAR OF UNCERTAINTY
We are living in the time of the most overwhelming change to lending compliance rules and to the structure of the regulatory agencies that enforce the rules since civil rights and consumer protection rules were first written in the late 1960s. We hope the picture will soon develop enough so we can discern the future of compliance. While the Fed has already begun to wind down it’s regulation writing activities, as evidenced by shelving the […]