All in Regulatory Update

OCC’s 2022 Annual Report

Adam Witmer
Regulatory Update

On January 5, 2023,, the OCC issued its annual report to Congress which provides an overview of the condition of the federal banking system. The annual report can be beneficial to compliance professionals as it discusses the OCC's strategic priorities and details agency regulatory and policy initiatives.

Escrow Exemption Threshold for 2023

Adam Witmer
Regulatory Update, Regulation Z

On December 27, 2022, the CFPB announced the annual adjustment to the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan under Regulation Z. These changes reflect updates to the exemption from TILA’s escrow requirement of creditors that, together with affiliates that regularly extended covered transactions secured by first liens, had total assets of less than $2 billion (adjusted annually for inflation) and the exemption the Bureau added, by implementing section 108 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), for certain insured depository institutions and insured credit unions with assets of $10 billion or less (adjusted annually for inflation).

2023 HMDA Exemption Threshold

Adam Witmer
Regulatory Update, HMDA

On December 27, 2022, the CFPB adjusted the HMDA exemption threshold from $50 million to $54 million. The adjustment is based on the 8.6percent increase in the average of the CPI-W for the 12-month period ending in November 2022 (up from 1.3 in 2020 and 4.7 in 2021). Therefore, banks, savings associations, and credit unions with assets of $54 million or less as of Dec. 31, 2022, are exempt from collecting data in 2023.

HUD Requests Information on Disaster Recovery Funds Allocation

Adam Witmer
Regulatory Update

On December 20, 2022, the HUD released two new Requests for Information (RFIs) on how to simplify, modernize, and more equitably distribute critical disaster recovery funds: Community Development Block Grant Disaster Recovery (CDBG-DR) and Mitigation (CDBG-MIT). The requests for public feedback is part of HUD’s Climate Action Plan, which emphasizes both equity and resilience in disaster recovery, as well as the Biden-Harris Administration’s commitment to strengthening low- and moderate-income communities.

Agencies Extend Their Statement Regarding Extensions of Credit to Certain Investment Funds

Adam Witmer
Regulatory Update, Regulation O

On December 22, 2022, the OCC, FRB, and FDIC issued a revised interagency statement to extend the “Extension of the Revised Statement Regarding Status of Certain Investment Funds and their Portfolio Investments for Purposes of Regulation O and Reporting Requirements under Part 363 of FDIC Regulations.” The prior interagency statement, which was issued on December 17, 2021, was set to expire on January 1, 2023.

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