Archive

Third Party Relationships: Guidance for Community Banks

Last week, the OCC (Office of the Comptroller of the Currency), the Board of Governors of the Federal Reserve System, and the FDIC (Federal Deposit Insurance Corporation) collectively issued guidance for community banks on Third-Party Risk Management. The guide, coming in at around 30 pages, aims to help community banks develop and implement effective third-party risk management practices and important considerations for each state of the third-party risk management life cycle. We’ve developed a training […]

In Case You Missed It: 2024 Lending Thresholds

Our job is to make yours a little easier. So, in case you missed their release, we’ve compiled 2024’s lending threshold changes (including historical data) and developed convenient tables to help you keep it all straight. You can find all the 2024 lending thresholds by CLICKING HERE. The CFPB released and updated the following thresholds for 2024: The HMDA threshold was increased from $54 million in 2023 to $56 million in 2024. The HPML Small […]

CFPB – RegCast Announced for July 25, 2023

If your institution is still questioning which compliance tier you fall into for Small Business Data Reporting, Section 1071.  If you have questions about covered transactions or just want to hear what the CFPB has to say on 1071 coverage.  You’re in luck. The CFPB announced this morning that they will host a RegCast on the small business lending rule.  It will provide information from the rule to help financial institutions determine whether they are […]

It’s Final! Section 1071 Small Business Data Collection

Today the Consumer Financial Protection Bureau (CFPB) finalized the Section 1071, Business Data Collection rule required by Congress to increase transparency in small business lending, promote economic development, and combat unlawful discrimination. The rules require Lenders to collect and report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit. The CFPB stated “the rule will work in concert with the Community Reinvestment Act, […]

DC District Court Rolls Back HMDA Threshold

On September 23, 2022, the United States District Court for the District of Columbia issued a Memorandum Opinion that reversed a section of Regulation C, the Consumer Financial Protection Bureau’s (CFPB) regulation which implements the Home Mortgage Disclosure Act (HMDA).   The April 2020 final HMDA rule increased the reporting threshold for closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100 covered loans originated in each of […]