Archive

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 […]

2018 CRA THRESHOLDS PUBLISHED

On December 21, 2017 the Federal Deposit Insurance Corporation, Federal Reserve Board of Governors, and the Office of the Comptroller of the Currency, together referred to as the Agencies, published 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. Annual adjustments to these asset-size thresholds are based on the change in the average of […]

FINAL AMENDMENTS TO CRA REGULATIONS

During mid-November the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies), published  a final rule to amend their respective Community Reinvestment Act (CRA) regulations. The rule amends the definitions of “home mortgage loan” and “consumer loan” and the public file content requirements to conform to revisions made by the Consumer Financial Protection Bureau to its Regulation C, which implements the Home Mortgage Disclosure Act. […]

INTERAGENCY HMDA KEY FIELDS PUBLISHED

The FRB, the FDIC, and the OCC recently issued Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with the HMDA’s requirements. Of 110 data fields, 37 are identified as key fields. In certain circumstances, however, examiners may determine it necessary to review additional HMDA data fields, as appropriate. Background The HMDA, which is implemented by Regulation C (12 CFR 1003), requires certain financial institutions to collect, record, […]