All in Regulatory Update

2019 Threshold for HPML Appraisal Exemption

Adam Witmer
Regulation Z, Regulatory Update

On November 21, 2018, the Agencies announced the 2019 threshold for smaller loan exemption from appraisal requirements for higher-priced-mortgage loans (HPMLs).  The Dodd-Frank Act amended the Truth in Lending Act to add special appraisal requirements for higher-priced mortgage loans, including a requirement that creditors obtain a written appraisal based on a physical visit to the home’s interior before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans of $25,000 or less and also provide that the exemption threshold will be adjusted annually to reflect inflation increases.

What to do if the NFIP Expires?

Adam Witmer
Flood, Regulatory Update

Every couple of years, the National Flood Insurance Program (NFIP) gets set to expire.  This is a result of the way Congress funds the program as the typically only renew the program for a few years at a time.  That is, if they renew the program on time.

Often times, the program is operating at a loss and Congress has a difficult time passing a long-term approval of the program.  When this happens, the program is typically reapproved on a short-term basis, but there are cases where the program expires.

Agencies Propose Increase to Residential Appraisal Threshold

Adam Witmer
Regulatory Update

On November 11, 2018, the federal agencies (FDIC, Federal Reserve, and OCC) released a notice of proposed rulemaking and request for comment.  In the release, the agencies are inviting comment on a proposed rule to amend regulations requiring appraisals for certain real-estate related transactions.  The proposed rule would increase the threshold level at or below which appraisals would not be required for residential real estate-related transactions. The proposed rule would increase the threshold from $250,000 to $400,000.

FDIC Seeks Comments on Small Dollar Lending

Adam Witmer
Regulatory Update

The FDIC has requested public comments on issues related to small-dollar lending by FDIC-Supervised financial institutions.  Specifically, feedback is being requested regarding consumer demand for small-dollar credit products, the supply of small-dollar credit products currently offered by banks, and what the FDIC can do to facilitate increase small-dollar lending.

CFPB Issues Statement on Payday Rule Reconsideration and Delayed Compliance Date

Adam Witmer
Regulatory Update

On October 26, 2018, the CFPB issued a statement regarding their planned payday rule.  Specifically, the CFPB explained that they expect to issue proposed rules in early 2019 that will reconsider the Payday, Vehicle Title, and Certain High-Cost Installment Loans rule.  They also plan to address the rule’s compliance date in this 2019 issuance. In their statement, the CFPB explained that they will make final decisions regarding the scope of the proposal closer to the issuance of the proposed rules. They also said, however, that

FDIC Proposes to Rescind Annual Disclosure Statement Requirements

Adam Witmer
Regulatory Update

On October 25, 2018, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule to rescind and remove its regulations relating to the disclosure of financial and other information by FDIC-insured state nonmember banks. Upon the removal of the regulations, applicable FDIC-regulated banks would no longer be subject to the annual disclosure statement requirement found in those regulations. The financial and other information that has been subject to disclosure by individual banks pursuant to these regulations is publicly available through the FDIC's website.

Load More