Archive

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 […]

HURRICANE MARIA AND CRA CONSIDERATIONS

On January 25, 2018 the federal bank regulatory agencies (Federal Reserve Board, FDIC, OCC) announced they will give favorable consideration under Community Reinvestment Act (CRA) regulations to institutions that are located outside of the U.S. Virgin Islands and Puerto Rico, which were designated as major disaster areas in the aftermath of Hurricane Maria, for bank activities that help to revitalize or stabilize these areas. The CRA encourages financial institutions to help meet local credit and […]

OCC CIVIL PENALTY INFLATION ADJUSTMENTS

On January 12, 2018 the Office of the Comptroller of the Currency (OCC) published a notice that sets the annual adjustments to the maximum amount of each civil penalty applicable to National Banks and Federal Savings Associations within the OCC’s jurisdiction. The adjustments, required by the Federal Civil Penalties Inflation Adjustment Act of 1990, serve to maintain the deterrent effect of civil penalties and to promote compliance with the law. The OCC (for National Banks)Civil […]