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When the Tide is Against You
Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]
HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption?
Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the […]
The Great Debate — Is This a Finance Charge?
If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly […]
Meet your Community’s Credit Needs for Fair Lending – Utilizing Regulation B’s Special Purpose Credit Program
“What are you doing to ensure diversity, equity and inclusion (DEI)?” That question routinely comes up during conference calls among us, clients, and regulatory agencies. Businesses, educational institutions, and non-profit organizations all are focusing on DEI. Financial institutions are no exception. In fact, regulatory agencies emphasize the importance of DEI in written communications about the Fair […]
CRA Public File Reminder
April 1st is known as April Fools’ day and a time to play tricks and pranks. But did you know on April 1, 1748, the Ruins of Pompeii were rediscovered by Spaniard Rocque Joaquin de Alcubierre? Guess it is time to rediscover the CRA Public File and make sure nothing ancient is inside! By now […]
CFPB Issues Changes to Rule on Higher-Priced Mortgage Loan Escrow Exemption
On February 17, 2021, the CFPB published a final rule to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The final rule also removed […]
The Fannie Mae and Freddie Mac Application: New and Improved?
The mortgage application, the 1003 or URLA – these are all synonyms for the standard residential mortgage application which has been changed. Navigating through these changes can be stressful; but we are here to help. Fannie/Freddie announced the release of the redesigned Uniform Residential Loan Application (URLA) on August 23, 2016. The changes would include […]
No Longer A HMDA Reporter – Fair Lending Still Applies
On April 16, 2020, The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds in Regulation C for financial institutions reporting data under the Home Mortgage Reporting Act (HMDA). A permanent threshold for collecting closed end mortgage reporting data went from 25 to 100 loans effective July 1, 2020. Also, open-end […]
HMDA and HPML Thresholds Bumped Up for 2021
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 […]
CRA Asset-size Thresholds Announced for 2021
The annual CRA asset-size thresholds for covered financial institutions were announced December 17, 2020 applicable for 2021. 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 1.29% increase in the CPI, the levels […]
