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2016 LENDING COMPLIANCE THRESHOLDS

Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]

THE CFPB INHERITS REGULATION M

The Consumer Leasing Act (CLA) was enacted in 1976 as an amendment to the Truth in Lending Act (TILA). The purpose of the CLA is to ensure meaningful and accurate disclosure of the terms of personal property leases for personal, family, or household use. The CLA and Regulation M require lessors to provide consumers with uniform cost and other disclosures about consumer lease transactions. The CLA has been implemented in Regulation M of the Board of […]