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CRA Thresholds Announced for 2020
The annual CRA asset-size thresholds for covered financial institutions were announced on December 30, 2019 applicable for 2020. 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 1.62% increase in the CPI, the […]
HMDA and HPML Thresholds Bumped Up for 2020
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 due to the annual percentage increase in the Consumer Price Index for Urban Wage […]
FinCEN Issues Guidance on Providing Financial Services to Hemp-Related Businesses
FinCEN and the regulators kicked off the holiday season by providing the industry with some clarification on the BSA implications of banking hemp-related businesses. In the News Release and Guidance, FinCEN said: “Because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act, banks are not required to file a Suspicious […]
314(a) and 314(b) Information Sharing: Is there a Difference?
The goal of my article is to help BSA staff have a clearer understanding of the differences between mandatory and voluntary information sharing. TCA’s BSA Action Team (BAT) wants to point out some key observations based on our BSA audits. In BSA, information requests are commonly referred to as sections 314(a) and 314(b) of the […]
Regulation Z and Regulation M Dollar Thresholds for 2020
The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds, which are tied to the Consumer Price Index, for Regulation Z and Regulation M exemptions. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators have released the new […]
SAFE Act MLO Registration Renewal Period Starts November 1 Check Current Registrant’s Names
It’s that time again. The NMLS 2019 Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their NMLS […]
Legislative and Regulatory BSA/AML Changes
Despite the collective efforts of law enforcement and BSA risk managers across the country, the United States is not doing the best job of finding effective and efficient ways to combat money laundering. Regulatory and legislative efforts, which are the truly meaningful actions that could be taken, are currently being worked on in Washington. A […]
HMDA Open-End Credit Threshold Maintained through 2021
On October 10, 2019, the CFPB released a final rule (not yet published in the Federal Register) extending the current 500 open-end credit threshold until January 1, 2022. This new rule is effective on January 1, 2020. In addition to the rule above, the Bureau has issued an Executive Summary and an “unofficial, informal” redline […]
Appraisal Threshold Increased to $400,000
Get ready to update those policies and procedures! On September 27, 2019, the OCC, FDIC and FRB, in concurrence with the CFPB, published a revision to the appraisal rules at 12 CFR 34, 225 and 323 increasing the threshold amount where a residential real estate transaction requires a state-licensed, certified appraiser from $250,000 to $400,000. […]
Ready for HDMA 2020?
Well, the CFPB is well on the way! On September 25, 2019, they released the 2020 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides timing and changing references of “2019” to “2020,” the changes appear to be items like updated descriptions and instructions for certain fields and revisions […]
