All in Regulatory Update

MOU Between CFPB & Department of Education

Adam Witmer
Regulatory Update

On 2/3/2020, the Consumer Financial Protection Bureau (Bureau) and the U.S. Department of Education (ED) announced a renewed coordination agreement - through a Memorandum of Understanding (MOU) - in order to better serve student loan borrowers.  In doing this, the agencies will share complaint information from borrowers and regularly to discuss observations about the nature of complaints received, characteristics of borrowers, and available information about resolution of complaints. The MOU more clearly defines…

CFPB Updates HMDA Guide

Adam Witmer
Regulatory Update, HMDA

On January 23 of 2020, the CFPB released their latest version (v.4) of their HMDA Small Entity Compliance Guide. The updates in this version of the guide were made to align the guide with the October 10, 2019 final rule which implements the partial exemption for small filers.

CFPB Fines Bank for Credit Card Dispute Process

Adam Witmer
Regulatory Update

On 1/30/2020, the CFPB filed suit against Citizens Bank, N.A. (Providence, Rhode Island) based on allegations that the bank violated the Truth in Lending Act (TILA) and its implementing Regulation Z, including violations of amendments to TILA contained in the Fair Credit Billing Act and the Credit Card Accountability Responsibility and Disclosure Act.

OCC Hammers Former Wells Fargo Execs with Fines

Adam Witmer
Regulatory Update, Compliance Management

On January 23, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of charges against five former senior executives of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, and announced settlements with the bank’s former Chief Executive Officer (CEO) and other members of the bank’s operating committee - including the former chief auditor, a former risk officer, former general counsel, and a former executive audit director.

This notice of charges is of particular interest to compliance and audit professionals as risk managers, auditors, and general counsel don’t typically appear in these types of charges.

The notice of charges alleges these executives…

Overview of CRA Proposal

Overview of CRA Proposal

Adam Witmer
CRA, Regulatory Update

In this Compliance Clip (video), Adam briefly discusses the recent CRA proposal by providing an overview of the goals of the proposal. Adam also discusses how, if passed as proposed, this new rule would have some major changes to Assessment Areas that may have negative effects on banks. Comments are due soon on this proposal, so watch this video to learn how the changes might affect your bank.

NCUA Releases Priorities for 2020

Adam Witmer
Regulatory Update

On January 7, 2020, the NCUA announced that it had issued its annual letter to credit unions listing its 2020 supervisory priorities as well as updates on regulations and the agency’s modernization programs.

The letter includes a summary of recent statutory and regulatory updates, including additional guidance on serving legal hemp businesses; changes in the appraisal threshold for commercial real estate transactions; the amended supervisory committee audits rule, which took effect Jan. 6; and the amended public unit and nonmember shares rule, which takes effect Jan. 29. For 2020, the NCUA has listed the following as supervisory priorities:

CRA Proposal Published

Adam Witmer
CRA, Regulatory Update

The long awaited CRA proposal was published in the Federal Register on January 9, 2020, meaning that comments on the proposed rule are due on March 9, 2020. This joint proposal between the OCC and FDIC did not include the support of the Federal Reserve, who currently have a slightly different take on how CRA regulations should be revised (according to comments by Federal Reserve Governor Lael Brainard on January 8, 2020). As we have explained before, this would be the first substantial update to the rules in nearly 25 years if the rule is finalized. According to the release, the proposed rules are intended to do a number of things including:

Agencies Adjust CRA Asset Size Thresholds

Adam Witmer
CRA, Regulatory Update

As is the case each year, the regulatory agencies have adjusted the asset size threshold under the Community Reinvestment Act for 2020. The “small institution” asset threshold has increased from 1.284 billion to 1.305 billion, while the “intermediate small institution” asset threshold has increased from 321 million in 2019 to 326 million in 2020.

Load More