It has been years since the federal financial institution regulatory agencies have overhauled the Community Reinvestment Act regulations, but they are working on a total revision right now. And they are constantly tinkering with the rules. The agencies use the CRA regulations to advance social policy. The changes impact how your rating is determined and what activities receive community development credit. Recent Revisions Bankers should view CRA ratings as a game. They need to learn […]
Category: Lending Compliance
YEAR-END HMDA NEWS
As part of the usual year-end flurry the Federal Reserve Board published its annual notice of the asset-size exemption threshold for depository institutions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The asset-size exemption for depository institutions will increase to $40 million based on the annual percentage change in the Consumer Price Index for Urban Wage Earners and Clerical Workers for the twelve-month period ending in November 2010. Depository institutions with assets […]
CRA – UPDATED THRESHOLDS FOR SMALL AND INTERMEDIATE-SMALL FINANCIAL INSTITUTIONS
On December 21st the federal bank regulatory agencies announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. The annual adjustments are required by the CRA rules. The annual adjustments are based on the change in the average of the Consumer Price Index (CPI) for urban wage earners and clerical workers, not seasonally adjusted, […]
SAFE ACT UPDATE
What’s the latest news on the SAFE Act? Expect to see a joint announcement before the end of the week that the National Registry will begin accepting MLO registrations on January 31, 2011. So what does this mean for you? You should already have your SAFE Act policy and procedures in place. They were required by October 1, 2010. If you haven’t yet identified which of your employees are MLOs you should do so between […]
The FACT Act’s Risk-Based Pricing Rules (Part 1 – The Big Picture)
Effective January 1, 2011 section 311 of the FACT Act requires a risk-based pricing notice. The notice is required when a person both: (1) Uses a consumer report in connection with an application for, or a grant, extension, or other provision of, credit to that consumer that is primarily for personal, family, or household purposes; and (2) Based in whole or in part on the consumer report, grants, extends, or otherwise provides credit to that […]