Archive

PENDING LENDING ISSUES

Can we see the light at the end of the tunnel? Maybe faintly. Truth-in-Lending/RESPA Integrated Disclosures (TRID) – The biggest pending issue is the TRID rules that are effective August 1, 2015. Some vendors have delivered updates to loan origination software for testing. Policies, procedures, and training need to be completed. But it is appears likely that most lending institutions will complete all required tasks by the deadline. Some, like the banker I talked to […]

FINAL RISK RETENTION RULES

On October 22, 2014 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission jointly issued a final rule to implement the credit risk retention requirements of section 15G of the Securities Exchange Act of 1934 (15. U.S.C. 78o-11), as added by section 941 of […]

PROPOSED FLOOD REGULATIONS

Recently the Office of the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Farm Credit Administration, the National Credit Union Administration (jointly referred to as the Agencies) issued 166 pages of proposed rules for loans in areas having special flood hazards. The revisions to existing rules are based on changes from the Biggert-Waters Flood Insurance Reform Act of 2012. Comments are being accepted until December 10, 2013. The Agencies […]

NEW RISK RETENTION (QRM) PROPOSAL

On August 28 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule the agencies issued in 2011 to implement […]

PROPOSED REVISIONS TO INTERAGENCY CRA QUESTIONS AND ANSWERS

The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies) are proposing to clarify their Interagency Questions and Answers Regarding Community Reinvestment to address several community development issues. The Questions and Answers were first published under the auspices of the Federal Financial Institutions Examination Council (FFIEC) in 1996, and were last revised on March 11, 2010. The Agencies propose to: Revise five questions and answers, […]