All in Regulatory Update

2019 HMDA Exemption Threshold

Adam Witmer
HMDA, Regulatory Update

On December 31, 2018, the CFPB adjusted the HMDA exemption threshold from $45 million to $46 million.  The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. Therefore, banks, savings associations, and credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting data in 2019.

OCC Releases Fall 2018 Semi-Annual Risk Perspective

Adam Witmer
Regulatory Update

Earlier this month (12/3/18), the OCC released their semi-annual risk perspective for the fall of 2018.  The report covers risks facing national banks and federal savings associations based on data as of June 30, 2018. The report presents information in five main areas: the operating environment, bank performance, special topics in emerging risk, trends in key risks, and supervisory actions. It focuses on issues that pose threats to those financial institutions regulated by the OCC and is intended as a resource to the industry, examiners, and the public. The report also includes several compliance and BSA-focused perspectives on trending challenges facing OCC-regulated banks.

CFPB Keeps Name

Adam Witmer
Regulatory Update

When the CFPB announced last June that they were beginning rebranding efforts to change the name of the Consumer Financial Protection Bureau to the Bureau of Consumer Financial Protection - or BCFP - I had my doubts. Over the last few months, I found myself feeling like some sort of geeky compliance-like rebel every time I…

CFPB Fair Lending Report to Congress

Adam Witmer
Regulatory Update

On December 4, 2018, the CFPB released their annual fair lending report to Congress regarding the fair lending activities that took place in 2017.  Traditionally released during April of each year, this years report comes nearly 20 months after the last annual fair lending report to Congress, and is the first report issued by the CFPB under a director different than Richard Cordray, who oversaw the first five reports to congress.

FinCEN Issues Statement to Cultivate BSA/AML Innovation

Adam Witmer
BSA, Regulatory Update

On December 3, 2018 FinCEN and the joint agencies released an advisory to encourage and support the implementation of responsible innovation and new technology in the financial system.  The advisory encourages banks and credit unions to take innovative approaches to their Bank Secrecy Act (BSA) programs for combating money laundering, terrorist financing, and other illicit financial threats.  

Fed & CFPB Reopen Comments & Proposal for Reg CC Proposed Rule

Adam Witmer
Regulation CC, Regulatory Update

On 11/20/18, the CFPB and Federal Reserve jointly issued a 58 page “proposed rule and reopening of comment period for existing proposed rule” for Regulation CC.  This request for comment does two things as the proposal would first implement new changes to the Expedited Funds Availability Act and also provides an additional opportunity for public comment on the 2011 funds availability proposal that was never finalized.

Comments must be received within 60 days after the date of publication to the Federal Register.

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