Archive

FINAL AMENDMENTS TO CRA REGULATIONS

During mid-November the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies), published  a final rule to amend their respective Community Reinvestment Act (CRA) regulations. The rule amends the definitions of “home mortgage loan” and “consumer loan” and the public file content requirements to conform to revisions made by the Consumer Financial Protection Bureau to its Regulation C, which implements the Home Mortgage Disclosure Act. […]

INTERAGENCY HMDA KEY FIELDS PUBLISHED

The FRB, the FDIC, and the OCC recently issued Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with the HMDA’s requirements. Of 110 data fields, 37 are identified as key fields. In certain circumstances, however, examiners may determine it necessary to review additional HMDA data fields, as appropriate. Background The HMDA, which is implemented by Regulation C (12 CFR 1003), requires certain financial institutions to collect, record, […]

HMDA EXAMINER TRANSACTION TESTING GUIDELINES

The Federal Financial Institutions Examination Council (FFIEC) recently issued FFIEC Home Mortgage Disclosure Act Examiner Transaction Testing Guidelines (guidelines). Examiners will use the guidelines to assess the accuracy of data that institutions collect and report under the Home Mortgage Disclosure Act (HMDA). The guidelines, which apply to data collected and reported beginning in 2018: Describe the data sampling process and explain how examination staff go about determining whether errors in each data field reviewed exceed […]

OCC GUIDANCE ON VIOLATIONS

On May 23, 2017 the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-18 to update its policies and procedures regarding violations of laws and regulations. The updated guidance: Communicate violations using a consistent format: Legal citation and description Summary of relevant statutory or regulatory requirements Facts supporting the violation and root cause(s) Corrective action(s) required Board and management’s commitment(s) to corrective action Reinforce the importance of timely and thorough follow-up and […]

AGENCIES PROPOSE PRIVATE FLOOD INSURANCE RULES

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA) have issued a new proposal to amend their regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). The proposed rule […]