Archive

FLOOD INSURANCE COMPLIANCE IN RESPONSE TO THE CORONAVIRUS

On May 6, 2020 the Federal Reserve Board issued Consumer Affairs letter CA 20-7 on the topic of Flood Insurance Compliance in Response to the Coronavirus. On March 9, the Federal Reserve Board and the other federal financial institution regulatory agencies and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by the coronavirus.Since that time, the Federal Reserve Board […]

AGENCIES DEFER APPRAISALS

On April 14, 2020 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation,  Office of the Comptroller of the Currency,  National Credit Union Administration,  and the Consumer Financial Protection Bureau (jointly, the agencies) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the interagency appraisal regulations. The agencies are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly […]

REGULATION O MODIFIED FOR PPP LOANS

On April 17 the Federal Reserve Board published an interim final rule that excludes loans that are guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from many of the requirements of Regulation O. The rule is effective upon publication in the Federal Register, which is expected soon. The comment period expires 45 days after publication in the Federal Register. The final rule excludes from all requirements of Regulation O, except for the executive […]

AVAILABILITY OF SOFR DATA

Last month we published an article entitled Are You Libor Ready?  On February 13 the Federal Reserve Bank of New York issued an Operating Policy Statement regarding publication of Secured Overnight Financing Rate (SOFR) averages and a SOFR Index to assist the transition to the new index. Publication of 30-, 90-, and 180-day SOFR Averages as well as a SOFR Index will begin March 2, 2020, in order to support a successful transition away from U.S. dollar […]

AGENCY CRA MANEUVERS

There has been recent activity on the proposed Community Reinvestment Act (CRA) regulations, but it is not clear whether the process is moving in a positive direction or not. Brainard Explains FRB Position The Federal Reserve Board (FRB) decided not to join the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Company (FDIC) in issuing the proposed revisions to the CRA regulations. On January 8, 2020 FRB Governor Lael Brainard […]