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I have always enjoyed fruit. When I was a kid we always had a selection of fruits in the house, and on rare occasions we had a more exotic fruit, like figs. Most of my family didn’t like figs, so my Mom and I always split them. They were quite a treat. I haven’t had any figs in a while, but soon we all will have more FIG than we want. Final revisions to Regulation […]

Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]

Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements […]

On October 15, 2015 the Consumer Financial Protection Bureau (CFPB) published revised Regulation C rules, which implement the Home Mortgage Disclosure Act. The revisions are effective for the most part on January 1, 2018, certain provisions are phased in through January 1, 2020. The revisions impact: Coverage – Coverage rules are slightly revised, but do not qualify as a major item on anyone’s list. The CFPB is playing this as meaningful reduction of regulatory burden. […]

We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to […]