David Mulkerin

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B Prepared for Compliance in Commercial Lending

It’s common for many lenders to believe that commercial lending is exempt from federal compliance regulations. However, this would be untrue – commercial loans are subject to the following compliance regulations: Regulation C/HMDA, Flood Disaster Protection Act, and Regulation B/ECOA. This article will focus on only one the regulations above – Regulation B. Under this […]

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Deposit Insurance Changes for Trusts and Mortgage Servicing Accounts

On January 21, 2022 the FDIC notified insured Institutions of simplification for the calculation of Deposit Insurance for Trust Accounts and Mortgage Servicing Accounts which will be effective April 1, 2024 (so, plenty of time to ease into the change). If you don’t want to read the 62-page regulation, you can always read on, or

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HMDA and HPML Thresholds Bumped Up for 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 Index for Urban Wage

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