David Mulkerin

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CFPB Funding Mechanism Determined Valid

The Supreme Court released their decision in the Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd. case, which was brought to challenge the funding of the CFPB as inconsistent with the Appropriations Clause. The challengers argued that this funding mechanism violated the appropriations clause, which provides that “no money shall be

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FDIC Signage and Advertising – Things They Are A-Changin’

On December 20, 2023 the FDIC approved and issued a final rule regarding changes to 12 CFR 328: rules for the use of FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentations of Insured Status, and Misuse of the FDIC’s Name or Logo. The updated rules are effective April 1, 2024, with a mandatory compliance

FDIC Signage and Advertising – Things They Are A-Changin’ Read More »

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HMDA and HPML Thresholds Bumped Up for 2024

On December 18, 2023, 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

HMDA and HPML Thresholds Bumped Up for 2024 Read More »

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024

On November 13, 2023, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections

HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024 Read More »

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