Earlier this month, the CFPB launched a new “Innovation” page on their website which promotes the initiatives of the newly formed Office of Innovation.  The Office of Innovation was formed in July of 2018 with a goal of encouraging consumer-friendly innovation and carrying on the work that was being done under Project Catalyst.  The new Innovation webpage comes just about a month after the CFPB proposed a revision to their policy to encourage trial disclosure programs (9/10/18).

On October 17, 2018, the CFPB published its rulemaking agenda for the Fall of 2018.  This is the second rulemaking agenda under Acting Director Mick Mulvaney. The agenda indicates that the information is current as of August 30, 2018 and identifies items the  CFPB “reasonably anticipates having under consideration during the period from October 1, 2018, to September 30, 2019.”

As is the case each month, the FDIC and OCC have released lists of performance evaluations from financial institutions receiving ratings during September of 2018.  Banks and savings associations subject to CRA examinations - and especially their CRA Officers who are responsible for CRA compliance - can greatly benefit from reviewing CRA performance evaluations that their regulators publish on similarly sized banks.  Specifically, reviewing Outstanding performance evaluations can often show a bank what unique steps can be taken to get extra CRA credit during an examination while Substantial NonCompliance ratings can explain what an insufficient CRA program looks like.

On October 16, 2018, the OCC, Federal Reserve, and FDIC published new FAQs regarding appraisals and evaluations for real estate transactions.  These FAQs clarify existing regulatory requirements and guidance that is found in two previous issuances:the 2010 Interagency Appraisal and Evaluation Guidelines and the 2016 Interagency Advisory on Use of Evaluations in Real Estate-Related Financial Transactions.

On October 15, 2018, the OCC issued a Bulletin (2018-38) announcing the updating of three booklets: “Agricultural Lending,” “Oil and Gas Exploration and Production Lending,” and “Trade Finance and Services.”  These booklets are part of the Comptroller’s Handbook and are used by examiners for their supervision and examinations of these areas.