David Mulkerin

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FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion

Compliance IQ / By

The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating …

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community reinvestment act

April 1st is Fast Approaching: Did You Update Your CRA Public File?

Fair Lending/CRA, Special Release / By

April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update. Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your …

April 1st is Fast Approaching: Did You Update Your CRA Public File? Read More »

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HMDA News and Census Tract Updates

Essential Compliance Consulting, HMDA, Special Release / By ,

Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated …

HMDA News and Census Tract Updates Read More »

community reinvestment act

CRA Asset-size Thresholds Announced for 2023

Essential Compliance Consulting, Fair Lending/CRA, Special Release / By

The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. 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. …

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mortgage loan disclosure

HMDA and HPML Thresholds Bumped Up for 2023

Essential Compliance Consulting, Special Release / By

On December 28, 2022, 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 …

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New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections

Essential Compliance Consulting, Special Release / By

Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase …

New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections Read More »

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