All in Regulatory Update

NCUA Increases CRE Threshold to $1M

Adam Witmer
Regulatory Update

On July 18, 2019, the NCUA released a rule that amends their policy requiring appraisals for certain transactions, including increasing the threshold below which appraisals are not required for commercial real estate transactions from $250,000 to $1,000,000. In addition to this, the rule does three other things: (1) it restructurs the rule to enhance clarity; (2) it exempts from the rule certain federally related transactions involving real estate in a rural area; and (3) is makes conforming amendments to the definitions section. The rule is not yet final, but will be so 90 days after publication in the federal register.

CFPB Releases Annual Fair Lending Report for 2018

Adam Witmer
Regulatory Update, Fair Lending, Regulation B

On June 28, 2019, the CFPB released their annual report on fair lending.  Coming just seven months after the last annual report to congress (12/4/18), this annual report to Congress describes the Bureau’s fair lending activities in innovation, outreach, prioritization, guidance and rulemaking, supervision, and enforcement for calendar year 2018.  This is the first report released under new CFPB Director, Kathleen Kraninger.

NOTE: The 2018 CFPB fair lending report to Congress will be included in our 2Q 2019 Regulatory Update program, which will be released in July of 2019, covering all of the regulatory changes that a compliance professional needs to be aware of from the activity that occurred during the 2nd Q of 2019.

FDIC Updates Exam Manual

Adam Witmer
Regulatory Update

On 7/2/19, the FDIC announced updates to their Consumer Compliance Examination Manual (CEM) which examiners utilize when conducting compliance examinations. The manual contains exam procedures for consumer compliance regulations, the Community Reinvestment Act rules, and other supervisory requirements and helps to provide consistency among examiners when conducting examinations.

CFPB Holds Symposium on Abusive Acts or Practices

Adam Witmer
Regulatory Update, UDAAP

On June 25, 2019, the CFPB held a symposium on abusive acts or practices. This symposium was the first in a series aimed at stimulating a proactive and transparent dialogue to assist the Bureau in its policy development process, including possible future rulemakings. The CFPB has explained that the format of each symposium will include a discussion panel of experts with a variety of viewpoints on the topic. The recent abusive acts or practices symposium included two panels of UDAAP experts and also included

URLA Implementation Date Delayed Again

Adam Witmer
Regulatory Update, Compliance Management

On June 12, 2019, the Federal Housing Finance Agency (FHFA), Fannie Mae, and Freddie Mac announced that the optional use period for the redesigned Uniform Residential Loan Application (URLA) form has been delayed again.  It was planned that the redesigned URLA could be used starting on July 1, 2019 with required use by January 1, 2020. This announcement delays the optional use period for the new URLA, meaning that lenders should not yet begin using this form. 

CFPB Releases Regulation CC Amendments (Video)

CFPB Releases Regulation CC Amendments (Video)

Adam Witmer
Regulation CC, Regulatory Update

In this Compliance Clip (video) Adam provides an overview of the Regulation CC amendments that were released on June 24, 2019. While these amendments are really just a small part of what is yet to come (probably very soon), these amendments will cause a number of challenges for financial institutions. First of all, the $200 and $5,000 thresholds have been increased for inflation - and will continue to be increased for inflation on a regular basis. Secondly, each time the threshold is increased, a change of terms notice is going to need to be delivered to applicable customers. Finally, there are a few other minor changes in this new final rule, which Adam explains in this video.

FDIC Creates Consumer Compliance Supervisory Highlights

Adam Witmer
Regulatory Update

On June 13, 2019, the FDIC released a new publication called Consumer Compliance Supervisory Highlights.  This publication includes a high-level overview of consumer compliance issues identified during 2018 by the FDIC during their supervision of state non-member banks and thrifts.  As stated in their release (FIL-31-2019), the purpose of this publication is to increase transparency with the FDIC’s supervision activities.

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