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2023 HMDA GUIDE

The federal bank regulatory agencies are announcing the Federal Financial Institutions Examination Council’s (FFIEC) revised “A Guide to HMDA Reporting: Getting It Right!” (2023 guide). The 2023 guide provides resources to help banks1 comply with the Home Mortgage Disclosure Act (HMDA) and Regulation C, its implementing regulation (12 CFR 1003). The 2023 guide reflects a technical amendment to the 2020 HMDA rule to adjust the loan volume thresholds effective January 1, 2023,2 for reporting HMDA data on […]

UPDATE ON APPRAISALS AND DISCRIMINATION

On February 14, 2023, the Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, U.S. Department of Housing and Urban Development, National Credit Union Administration, Federal Reserve Board, U.S. Department of Justice, Office of the Comptroller of the Currency, and the Federal Housing Finance Agency (the “agencies”) sent a joint letter to The Appraisal Foundation (TAF) expressing concerns with the Fourth Exposure Draft of Proposed Changes for the 2023 Edition of the Uniform Standards of Professional Appraisal Practice […]

FHA PROPOSED ACTIONS REGARDING APPRAISALS

Recently the Department of Housing and Urban Development released a draft Mortgagee Letter. The proposed letter establishes a process for mortgagees when a borrower requests a review of the appraisal results associated with their application for an FHA-insured mortgage. On June 1, 2021, President Biden announced the creation of an Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) to combat bias in home appraisals. FHA is committed to strengthening safeguards against unlawful discrimination […]

2023 CRA ASSET-SIZE THRESHOLDS

On December 19, 2022, the Federal Reserve Board and the Federal Deposit Insurance Corporation announced the 2023 updated asset-size thresholds used to define “small bank” and “intermediate small bank” under their Community Reinvestment Act (CRA) regulations. Annual adjustments to these asset-size thresholds are based on the average change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which is a measure of inflation. As a result of the 8.60 percent increase […]

REGULATION O – RECENT ENFORCEMENT ACTION

Last month, the Federal Reserve Board (FRB) announced a $9,524,000 fine to be imposed on EagleBank, of Bethesda, Maryland for violations of Regulation O. The bank improperly extended credit to entities owned or controlled by its then-CEO and Chairman, Ronald D. Paul. The FRB: Found that EagleBank had deficient internal controls over insider lending practices between 2015 and 2018: Which allowed the bank to extend credit totaling $99 million to entities that Paul owned or controlled, including certain […]