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.

Fair Lending for Lenders is $100 Off!

Adam Witmer

Our Fair Lending for Lenders is currently on sale for $100 off the regular price.] Our Fair Lending for Lenders program provides a deep dive into fair lending, designed specifically for your loan officers and loan processors. The program can be completed in 2 hours, and we can set your organization up with a private portal for everyone in your organization to access. You can view the full curriculum of our Fair Lending for Lenders program - and watch an overview video of the program - at www.compliancecohort.com/fair-lending-for-lenders.

VIDEO: Appraisal Independence for Commercial Appraisals

VIDEO: Appraisal Independence for Commercial Appraisals

Adam Witmer

In this Compliance Clip (video), Adam answers the question of whether commercial lenders can select the appraiser for commercial loans. In other words, In other words, does the appraisal independence rules apply to commercial appraisals and commercial lenders? In addition, Adam explains how the independence rules apply to smaller financial institutions.

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.

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