Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]
Tag: Truth in Lending
CFPB RELEASES RURAL AND UNDERSERVED AREAS TOOL
This week the Consumer Financial Protection Bureau (CFPB) issued its Rural and Underserved Areas Tool linked here https://www.consumerfinance.gov/rural-or-underserved-tool/. The tool is designed to assist creditors in determining if properties are located in a rural or underserved area and eligible for certain exemptions from various requirements provided to certain small creditors under the CFPB’s mortgage rules. The Rural and Underserved Areas Tool is a the result of a final rule approved by the CFPB on September […]
CFPB SEMI-ANNUAL AGENDA
Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements […]
EXAMINATION EXPECTATIONS – WHAT AGENCIES ARE ON BOARD WITH CFPB?
Last week, the FDIC provided the industry with a Financial Institution Letter (FIL 43-2015) to detail what financial institutions can expect in terms of initial examinations after the October 3rd TRID implementation date. The first blog article in this series regarding TRID exam expectations can be found here. The Financial Institution Letter came after the CFPB released in mid-September the updated examination procedures the Bureau will rely on to complete initial exams. In July, Director […]
WHEN DO WE HAVE AN APPLICATION?
We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to […]