Archive

On December 12, 2019 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) announced a proposal to modernize the regulations under the Community Reinvestment Act (CRA) that have not been substantively updated for nearly 25 years. The proposed rules are intended to increase bank activity in low- and moderate-income communities where there is significant need for credit, more responsible lending, greater access to banking services, and improvements to […]

Like kids in a sandbox the regulators cannot agree on the rules of the game being played. In this case the game is the Community Reinvestment Act. The implementing regulations and examinations procedures have been in serious need of revisions for 25 years. The agencies seem to agree that changes are needed, they just can’t agree on the direction of the change. Last year Comptroller of the Currency Otting jumped the gun and published an […]

The previously announced $400,000 residential appraisal threshold is effective today (October 9, 2019) following publication of the final rule in yesterday’s Federal Register.

Recently the OCC, the FRB, the FDIC, the FCA, and the NCUA, through the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council, revised the Interagency Examination Procedures for the Flood Disaster Protection Act. The revised procedures reflect the February 2019 final interagency rule that addresses the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012. The updated procedures incorporate new sections that discuss: Mandatory acceptance of a […]

On July 31 the Office of the Comptroller of the Currency issued guidelines for requesting: Approval of a strategic plan (OCC Bulletin 2019-39); and Designation as a wholesale, limited purpose, or special purpose bank (OCC Bulletin 2019-40).