CRA In the Boardroom
As financial institutions face increasing pressure to demonstrate their commitment for economic stability in underserved areas and populations, the responsibility of the Board of Directors under the Community Reinvestment Act (CRA) has never been more critical in shaping strategies that serve both community and business interests. You may be thinking “How can the Board become
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Intent to Rescind Community Reinvestment Act (CRA)
On March 28, 2025, the FDIC, Federal Reserve Board and the OCC issued a joint press release to announce their intent to issue a proposal to rescind the Community Reinvestment Act (CRA) final rule issued in October 2023 and reinstate the CRA Framework that existed prior to the October 2023 final rule. The goal of
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Can a customer be held liable for $500 of a fraudulent transaction that occurred more than two business days after the loss of a mobile phone if the debit card number is saved to a mobile application?
The Reg E definition of an access device is a generic “card, code, or other means of accessing an account” so the debit card number does meet the definition of an access device. However, for the $500 liability tier to apply, 1005.2(b)(2) notes that the fraud must involve an “accepted access device” which must be
1071 Preparation Guide | Article 5 What is an Application Date?
Application dates are sometimes a foreign concept in commercial lending. However, now that 1071 is a reality, commercial divisions everywhere will have asked themselves, “When do I have a completed application?” and perhaps the most important question of the day, “What will define my application date?” In commercial lending, it’s not as simple to determine
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1071 Preparation Guide | Article 2 Identifying Stakeholders, Forming A Committee
Establishing a 1071 Implementation Committee is essential for your institution to ensure Regulation 1071 compliance. Your committee’s first order of business is preparing a risk assessment and reviewing the regulation to determine its impact on your processes and procedures. It also manages the project, prepares progress reports for stakeholders, addresses problems like delays and lack
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FinCEN Issues Final Rule for Beneficial Ownership Reporting
On September 29, 2022, FinCEN issued a final rule for Beneficial Ownership Reporting to support law enforcement efforts. The rule establishes timeframes for legal entities to report beneficial ownership information FinCEN as required by the Corporate Transparency Act (CTA). According to the publication, FinCEN will have rulemakings to: Establish rules for who may access the
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We are originating a HELOC loan to fully pay off an existing HELOC loan. Since there is no new money involved, would Right of Rescission apply?
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
Servicing Compliance Webinar Series: Adverse Action Requirements
It’s more than just saying “No” When are adverse action notices required? Adverse action notices requirements for denied deposit accounts Adverse action notice requirements for commercial customers Notice of incompleteness requirements How should files be documented when a customer withdraws an application. What’s the difference between a withdrawn application and an application which was approved
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Clarifying the Joint Intent Requirements at Application
Joint intent exceptions are a common finding in our compliance reviews. We have found that there are misconceptions on what constitutes joint intent and how it should be documented; most of the questions come from commercial versus consumer mortgage loan officers. Many of the questions we are asked include: Isn’t the joint financial statement enough
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