Archive

Agencies Announce Thresholds For TILA, Consumer Leasing, and Higher-Priced Mortgage Loans

Last Friday, October 4th 2024, The CFPB (Consumer Financial Protection Bureau) and the  Federal Reserve Board (FRB) announced the dollar thresholds used to determine which consumer credit and lease transactions in 2025 are subject to specific protections under Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing). The thresholds are adjusted annually based on the percentage increase in the CPI-W (Consumer Price Index for Urban Wage Earners and Clerical Workers). So, based on the […]

Applicability Date Extension for parts of CRA’s Final Rule

On March 21, 2024, the FDIC, FED, and OCC jointly issued an interim final rule that extends the applicability date of certain provisions in their Community Reinvestment Act (CRA) final rule issued in October 2023. The agencies also requested comments on the extension. The agencies extended the applicability date of the facility-based assessment areas and public file provisions from April 1, 2024, to January 1, 2026. Therefore, banks will not have to make changes to […]

AGENCIES PROPOSE NEW PRIVATE FLOOD INSURANCE Q&AS

On March 11, 2021, the OCC, Board, FDIC, FCA, and NCUA proposed to supplement the Interagency Flood Insurance Questions and Answers with new interagency questions and answers related to the private flood insurance rules. These newly proposed Questions and Answers Regarding Private Flood Insurance are in addition to the  Proposed Interagency Questions and Answers Regarding Flood Insurance that the Agencies released in 2020. In 2020 the Agencies stated in their proposed revisions that since the […]