On July 5, 2018 both the Office of the Comptroller of the Currency (OCC Bulletin 2018-19) and the Consumer Financial Protection Bureau issued statements regarding the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) amendments to the Home Mortgage Disclosure Act (HMDA). The President signed the EGRRCPA on May 24, 2018. Section 104 of the law amends HMDA. The EGRRCPA provides exemptions from certain HMDA requirements for insured depository institutions, with satisfactory or outstanding […]
Category: OCC
APPRAISAL REVISIONS TAKE EFFECT
On April 9, 2018 the Office of the Comptroller of the Currency (OCC); Board of Governors of the Federal Reserve System (Board); and Federal Deposit Insurance Corporation (FDIC) published a final rule to amend the agencies’ regulations requiring appraisals of real estate for certain transactions. The final rule increases the threshold level at or below which appraisals are not required for commercial real estate transactions from $250,000 to $500,000 and makes other changes. The final […]
MORE TALK OF CRA REVISIONS
On April 3, 2018 the U.S. Department of the Treasury released recommendations to modernize the Community Reinvestment Act (CRA). The recommendations were issued to the primary CRA regulators, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation. Treasury’s objective in developing these recommendations is to better align CRA activity with the needs of the communities that banks serve, while being conducted in a manner consistent with […]
CHANGE IN APPRAISAL THRESHOLD
On March 20, 2018 the FDIC board of directors approved a final rule to raise the appraisal thresholds for commercial real estate transactions from $250,000 to $500,000. The threshold for loans secured by one-to-four family residential properties will remain at $250,000. The final rule increases the commercial real estate appraisal threshold with three modifications from the proposal. First, the agencies have increased the commercial real estate appraisal threshold to $500,000 rather than $400,000 as proposed. […]
OTTING MISSTATEMENT
Last week Comptroller of the Currency Joseph M. Otting issued a statement after meeting with Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau. According to the news release (NR 2018-14) from the Office of the Comptroller of the Currency (OCC) Comptroller Otting stated “Acting Director Mulvaney has helped reduce the burden on the banking system by delaying implementation of his agency’s Home Mortgage Disclosure Act rule, committing to reconsider its payday lending rule, and […]