All in Regulatory Update

OCC Steps Back from CRA Rule

Adam Witmer
CRA, Regulatory Update

In somewhat of a surprise turn of events, the OCC announced on 5/18/2021 that it plans to reconsider its June 2020 CRA rule. This backstep comes for a rule that was released only by the OCC as the FDIC and Federal Reserve did not participate in this final rule and had not come to a consensus on CRA reform - meaning the OCC was planning to implement a new CRA rule on their own, rather than jointly with the other agencies. Interestingly enough, the 5/18/21 announcement comes almost one year after prior OCC Comptroller Joseph Otting - who was the primary person pushing for CRA reform - issued the final rule, and then just hours later announced that he would be stepping down from the OCC.

FDIC Requests Information on Digital Assets

Adam Witmer
Regulatory Update

On 5/17/2021, the FDIC announced that it is gathering information about insured depository institutions’ current and potential digital asset activities. In their release, the FDIC explains that banks are increasingly exploring the emerging digital asset ecosystem, so the FDIC has issued its request for information (RFI) to help inform its understanding of the industry’s and consumers’ interests in this area.

Agencies Extend Comment Period for AI Information

Adam Witmer
Regulatory Update

On 5/17/21, the Federal Reserve, CFPB, FDIC, NCUA, and OCC jointly announced that they extended the comment period on the request for information on financial institutions’ use of artificial intelligence (AI) until July 1, 2021. Comments were originally due by June 1, 2021, but this extension was made to allow stakeholders more time to coordinate and prepare their comments.

FDIC's 2021 Risk Review

Adam Witmer
Regulatory Update

On 5/11/21, the Federal Deposit Insurance Corporation (FDIC) published its 2021 Risk Review, which outlines a list of emerging risks in the U.S. banking system. According to the FDIC’s release, they began reporting key banking sector risks in its Risk Review publication in 2019, and this year’s report expands coverage of key risks during a time of heightened uncertainty.

CFPB Reports on Mortgage Challenges during Pandemic

Adam Witmer
Regulatory Update

On 5/4/2021, the CFPB released two reports where the CFPB explains that more work needs to be done to help mortgage borrowers coping with the COVID-19 pandemic and economic downturn. The first report documents that Black and Hispanic mortgage borrowers are much more likely to be delinquent or in a forbearance program than white borrowers. In a second report, the CFPB reports that overall mortgage complaints to the CFPB have risen to their highest level in three years.

FinCEN Reissues Geographic Targeting Orders

Adam Witmer
Regulatory Update, BSA

On 4/29/2021, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of a set of Geographic Targeting Orders (GTOs) that have been renewed several times now, the last renewal being in November 2020. These GTOs require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate and only apply to title companies in certain metropolitan areas. The purchase amount threshold remains $300,000 for each covered metropolitan area.

OCC Revises Credit Card Booklet

Adam Witmer
Regulation Z, Regulatory Update

On 4/29/2021, the OCC released Bulletin 2021-22 to announce they had issued a revised “Credit Card Lending” booklet of the Comptroller’s Handbook, which is prepared for use by OCC examiners in connection with the examination and supervision of national banks, federal savings associations, and federal branches and agencies of foreign banking organizations (collectively, banks).

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