On December 21, 2021, the FFIEC released the public disclosures for CRA data submitted for calendar year 2020. Note: If your institution does not report CRA small business, small farm or community development lending data, then this Special Release would not apply to you. Even if your institution is not a CRA reporter, a review […]
FFIEC Releases 2020 CRA Public Data Tables Read More »
The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price Index for Urban Wage
HMDA and HPML Thresholds Bumped Up for 2022 Read More »
Answer: Since the property is being deeded over to the borrower, the borrower is essentially purchasing the property for what is remaining Yes. Although no new money is being advanced, this is a new HELOC that will allow a customer to redraw on funds from the line once the loan is paid down. The Right
Answer: It depends. If your customer is simply leasing out the space to the virtual currency kiosk owner/operator and collecting “rent” payments, the owner of the kiosk is the MSB, not your customer. The owners of the kiosk are required to register with FinCEN as an MSB. Your due diligence on your customer would be
Answer: Since the property is being deeded over to the borrower, the borrower is essentially purchasing the property for what is remaining on the existing loan. Therefore, this would be reported as a Purchase.
The annual CRA asset-size thresholds for covered financial institutions were announced December 16, 2021 applicable for 2022. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. As a result of the 4.73% increase in the CPI, the levels
CRA Asset-Size Thresholds Announced for 2022 Read More »
Answer: Anything of value, regardless of the amount, that is given for a referral of business, would be considered a violation of Section 8. Unfortunately, the CFPB has not provided clarification on these types of “gifts,” so we have to rely on what the regulation says. RESPA does allow for “normal promotional or educational activity”;
Answer: During independent audits, TCA tests for initial and annual due diligence reviews of exempt customers. There are four requirements for a Phase II exemption. Five transactions that exceed reporting thresholds in a 12-month period. The customer has a transaction account for at least 2 months. The customer is organized in a U.S. State. The
What is a common finding TCA sees in exempting eligible customers from CTR reporting? Read More »
The OCC issued News Release 2021-133 on December 14, 2021, announcing the final rescinding of their June 2020 Community Reinvestment Act (CRA) Rule. The Final Rule will become effective as of January 1, 2022 and will apply to all national banks as well as to both federal and state savings associations. Financial institutions regulated by
Everything Old is New Again- OCC Rescinds CRA Rules Read More »
Answer: When the financial institution is notified of the death of a recipient, it must return all subsequent post-death benefit payments with a Return Reason Code R15 or R14. These codes notify the Federal agency of the recipient’s death. The financial institution may return any post-death benefits that have already posted by ACH without waiting
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