Archive

ARE YOU LIBOR READY?

Many financial institutions make consumer loans, residential mortgage loans, and commercial loans with pricing based on the London Inter-Bank Offered Rate (LIBOR). In 2017 the United Kingdom’s Financial Conduct Authority (the regulator that oversees the LIBOR panel) announced that, by the end of 2021, it will discontinue the index. The Federal Reserve Board of Governors and the Federal Reserve Bank of New York (FRBNY) in conjunction with the U.S. Treasury Department’s Office of Financial Research have […]

REGULATORS UNABLE TO AGREE ON FUTURE OF CRA

Like kids in a sandbox the regulators cannot agree on the rules of the game being played. In this case the game is the Community Reinvestment Act. The implementing regulations and examinations procedures have been in serious need of revisions for 25 years. The agencies seem to agree that changes are needed, they just can’t agree on the direction of the change. Last year Comptroller of the Currency Otting jumped the gun and published an […]

BOARD CONSIDERATION OF MUTUAL AID SOCIETY PLANS

The February 2019 revision to the flood insurance regulations provides a definition of a “mutual aid society” and describes the conditions under which a regulated lending institution may accept a flood protection plan issued by a mutual aid society. Within the Board’s Regulation H, 12 CFR 208.25(c)(3)(iv) enumerates those conditions. The first of the conditions for acceptability of a mutual aid plan requires that “the Board has determined that such plans qualify as flood insurance […]

UPDATED FLOOD INSURANCE EXAMINATION PROCEDURES

Recently the OCC, the FRB, the FDIC, the FCA, and the NCUA, through the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council, revised the Interagency Examination Procedures for the Flood Disaster Protection Act. The revised procedures reflect the February 2019 final interagency rule that addresses the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012. The updated procedures incorporate new sections that discuss: Mandatory acceptance of a […]