Archive

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 […]

OCC PUBLISHES CRA INFOGRAPHICS

The Office of the Comptroller of the Currency (OCC) has published a series of infographics to assist banks in understanding the requirements of the proposed interagency CRA rules. The proposed rules are an interagency effort. While the infographics come from the OCC, all banks, regardless of prudential regulator, will benefit from the information. The CRA NPR Infographics include: CRA Fact Sheet; Small Banks; Intermediate Banks; Large Banks; Wholesale or Limited Purpose Banks; and Large and […]

FFIEC UPDATES LIST OF DISTRESSED OR UNDERSERVED GEOGRAPHIES

On July 1, 2022 the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced the availability of the 2022 list of distressed or underserved nonmetropolitan middle-income geographies. These are geographic areas where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration pursuant to the definition of community development under the agencies’ regulations. Revitalization or stabilization activities in these geographies are eligible to […]

NEW INTERAGENCY QUESTIONS AND ANSWERS REGARDING FLOOD INSURANCE – FINALLY

On May 11, 2022, the Board of Governors of the Federal Reserve System, the Farm Credit Administration, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (jointly, the agencies) issued revised questions and answers (Q&As) regarding federal flood insurance law and the agencies’ implementing regulations. The Q&As: Replace those originally published by the agencies in 2009 and 2011 and consolidate Q&As proposed by the agencies […]