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HMDA and HPML Thresholds Bumped Up for 2019
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 […]
Important Update National Flood Insurance Program—What’s Going On?
On December 21, 2018, the President signed legislation that extended the National Flood Insurance Program’s (NFIP’s) authorization to May 31, 2019. All was well for another six months, or so everyone (including Congress) thought. On December 27th, FEMA ruled that the NFIP extension doesn’t allow for its continuation during the ongoing government shutdown. This decision […]
CRA Asset-size Thresholds Announced for 2019
The annual CRA asset-size thresholds for covered financial institutions were announced on December 20, 2018 applicable for 2019. 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 2.59% increase in the CPI, the […]
Will National Flood Insurance Program Expire?
On November 20, 2018, FEMA posted a press release reminding interested parties that the National Flood Insurance program (NFIP) expires at 11:59 p.m. on November 30, 2018. While FEMA is confident Washington will vote to reauthorize the NFIP, if a lapse were to occur, it would not impact policies already in effect. We will continue […]
Regulation Z and Regulation M Dollar Thresholds for 2019
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 regulatory protections. The regulators have released the new index limit for […]
Here We “GTO” Again Real Estate Geographic Target Orders Expande
On November 15, 2018, FinCEN announced the expansion of the existing real estate geographic target orders (GTO) to include 12 more metropolitan areas. As covered in previous TCA Special Delivery articles, a series of GTOs measures became effective March 1, 2016 which temporarily required certain U.S. title insurance companies in the Borough of Manhattan, New […]
Submit Comments to CRA Modernization Initiative
Several staff members of Thomas Compliance Associates (TCA) attended the recent CRA & Fair Lending Colloquium and obtained valuable information from the sessions. One theme that stood out and presenters stressed was that bankers can help shape the re-write of the Community Reinvestment Act (CRA) regulation. The Office of the Comptroller of the Currency (OCC) […]
What do CDD and EDD Mean? Part I: Customer Due Diligence
What is all the buzz about customer due diligence (CDD) and enhanced due diligence (EDD)? The expectations for CDD and EDD did not change with the addition of the 5th BSA pillar. The expected due diligence requirements were simply codified. TCA® first addressed this topic in depth in a 2015 article. What does that mean […]
FFIEC Releases 2017 CRA Public Data Tables
On October 25, 2018, the FFIEC released the public disclosures for CRA data submitted for the calendar year 2017. Institutions that report CRA data should go to the FFIEC website and download their disclosure tables for availability on request. The report should be made a part of your CRA Public File within three business days […]
Regulatory Announcements October 2018
Various regulatory agencies have released resources over the past couple weeks. As part of being a compliance partner and showing clients A Better Way with TCA, please see the following key insights. Appraisal FAQ Released On October 16, 2018, the OCC, FDIC and FRB released a joint Frequently Asked Questions document in response to comments […]
