Archive

CRA Modernization Final Rule

Earlier today, The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC), issued a final rule to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA). The CRA is designed to ensure federally insured banks meet the credit needs of the communities in which they do business, especially low- and moderate-income (LMI) communities.  The press release announcing the CRA Modernization’s final rule emphasizes that […]

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 […]

FEDERAL BANK REGULATORY AGENCIES CONTINUE TO IGNORE SEXUAL ORIENTATION AND GENDER IDENTITY ISSUES

On June 15, 2020, the United States Supreme Court in the case of Bostock v Clayton County declared that disparate treatment based on sexual orientation or gender identity is sex discrimination under federal law. It is the law of the land. On March 9, 2021, the Consumer Financial Protection Bureau (CFPB) issued an interpretative rule to amend Regulation B to clarify that disparate treatment based on sexual orientation or gender identity is sex discrimination under […]

$6 MILLION PENALTY FOR REGULATION Z VIOLATIONS

On September 27, 2022, the Office of the Comptroller of the Currency imposed a $6 million penalty on Sterling Bank and Trust of Southfield, MI for engaging in unsafe and unsound banking practices, including violations of the Truth in Lending Act and Regulation Z. Between approximately mid-2011 and December 2019, the Bank: Offered the Advantage Loan Program (“ALP”), a low-document mortgage loan program, which was the Bank’s primary loan product during this period. The Bank […]