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All in Regulatory Update
On October 24, 2019, the CFPB announced its third symposium in a series that started earlier in 2019. The most recent discussion will focus on Section 1071 of the Dodd Frank Act, which amends the Equal Credit Opportunity Act (ECOA) to require financial institutions to collect, report, and make public certain information concerning credit applications made by women-owned, minority-owned, and small businesses.
As has been the case with the other two symposiums, this program will
On October 8, 2019, the CFPB released their semi-annual report to Congress. This “Spring 2019” report covers the period beginning October 1, 2018 and ending March 31, 2019.
This report covers the following…
As we reported last week, the regulators issued joint guidance to increase the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000. The appraisal threshold adjustment was effective the day after publication in the Federal Register. Since the final rule was published on 10/8/19, the new $400,000 threshold is now in effect and can be utilized by banks on applicable loans.
For those looking for a comprehensive break-down of the new appraisal threshold rules, we will be offering training on this topic as both part of our 3Q 2019 Quarterly Compliance Update as well as a stand-alone product. Those programs will both be available in our store at www.compliancecohort.com/store over the next few weeks.
Over the last week, FinCEN updated their CTR Frequently Asked Question (FAQ) # 16 - for the third time in recent days. A few weeks ago, FinCEN started the process of changing how they want CTR filers to complete CTRs when a person has multiple “roles” in the transaction. Initially, FinCEN updated CTR FAQ 16 with a new answer, but then reverted to the original answer to FAQ 16 after apparent multiple calls from bankers questioning this change (that did not have an associated announcement or even changes to the CTR instructions). This week, we have received reports that FinCEN released a statement
On October 1, 2019, the Office of the Comptroller of the Currency (OCC) released its bank supervision operating plan for fiscal year 2020. This annual plan outlines how the OCC plans to focus their supervision of individual national banks, federal savings associations, federal branches, federal agencies, and technology service providers. In their announcement, the OCC explains that they plan to focus on the following areas for 2020:
On 9/30/19, the OCC issued updates to the "Bank Supervision Process," "Community Bank Supervision," "Federal Branches and Agencies Supervision," and "Large Bank Supervision" booklets of the Comptroller’s Handbook. Updates to Comptroller’s Handbook booklets are summarized in the "Table of Updates Since Publication" in the back of each booklet. Refer to the "Foreword" booklet of the Comptroller’s Handbook for more information regarding the OCC’s process for updating booklets. The updated booklets reflect the following:
On September 27, 2019, the regulators issued joint guidance to increase the threshold for residential real estate transactions requiring an appraisal from $250,000 to $400,000. This change represents the first change to the residential appraisal threshold since 1994. In their joint release, the regulators explain that this change will provide burden relief without posing a threat to the safety and soundness of financial institutions. While an appraisal will now no longer be required for real estate transactions under $400,000, financial institutions are still required to obtain
During the end of September, Congress extended the National Flood Insurance Program for another few months, through November 21, 2019. As the NFIP was set to expire at the end of day on September 30, 2019, this new extension marks the thirteenth temporary extension of the flood program within the last few years. As we have noted before, this large number of temporary extensions signal a desire by Congress to make long-term changes to the program. In fact, Congress has been working on a bipartisan 5 year extension, but have yet to come to an agreement on what that extension would look like. As you have already probably noted, these continued short term extensions are…
On 9/25/19, the CFPB announced the availability of their Filing Instructions Guide (FIG) for data collected in 2020 is now available. The FIG is a technical resource to help financial institutions file HMDA data collected in 2020 and reported in 2021. In conjunction with this, the CFPB also announced…
On 9/25/19, the CFPB published 4 FAQs on the SAFE Act. These FAQs clarify changes as implemented by the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The FAQs are effective as of November 24, 2019. The new FAQs answer the following questions…
