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HMDA and HPML Thresholds Bumped Up for 2025
On December 27, 2024 the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and on December 23, 2024 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 increases or decreases in the […]
CRA Asset-size Thresholds Announced for 2025
The annual CRA asset-size thresholds for covered financial institutions were announced by the FDIC and Federal Reserve on December 19, 2024 and by the OCC on December 23, 2024 applicable for 2025. The cutoff adjustments are based on the change in the CPI-W (Consumer Price Index) for each 12-month period ending in November, rounded to […]
HOEPA Calculation Worksheet for 2025 Loans
Tool to calculate whether your loan transaction is subject to HOEPA based on the points and fees and prepayment penalties paid by the borrower. Worksheets are updated annually to reflect changes loan amount thresholds. Select the worksheet based on the year the loan has been originated. Example: loan originated in December 2023 – select the HOEPA Calculation Worksheet 2023.01.
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Are there any requirements for specific disclosures on periodic home equity loan statements for consumers in bankruptcy? 12 CFR Part 1026.41 (Regulation Z) has requirements for closed-end consumer credit transactions but unclear about HELOCs.
Our review of Reg Z for open-end credit periodic statement requirements (1026.7) found nothing specific noted relating to loans in bankruptcy. The requirements only apply to closed-end credit under 1026.41. However, there may be state specific rules regarding statements and borrowers in bankruptcy. We recommend reaching out to your legal counsel or state banking association […]
The FDIC logo change was pushed until May 1, 2025, but my institution was wondering if the logo on our printed rate sheets given to customers upon request needs to be updated. My understanding is that the gold/black signs we have at the teller windows, and banker desks are NOT changing, and I think printed logos aren’t changing, but really, it’s mainly about the digital channels – and those need to be navy blue and black. So, if I’m correct, then the rate sheets do not require updates?
You are correct. Nothing pertaining to advertising is changing. The FDIC advertising rules stay the same. The gold/black signage, use of Member FDIC/FDIC-Insured that is all the same. So, on rate sheets, printed advertisements, social media, etc. there is no change. Lobby signage is an optional change. There is a provision to remove the signage […]
When will an institution have to comply with the upcoming 1071 Small Business Lending reporting requirements?
Compliance dates for 1071 will be enforced on a tier system. According to a release from the CFPB in June of this year, the final rule, which was to become effective August 29, 2023, was subject to a stay by a federal Texas court pending the outcome of the Supreme Court decision in CFPB v. […]
Is the SCRA Notice expired? The expiration date is November 30, 2024. Is there an updated version?
The SCRA Notice (HUD-92070) was implemented by HUD Mortgagee Letter 2006-28 and now mandated by the HUD Handbook 4000.1. The notice must: The form is technically “expired,” however since no new form has been issued yet by HUD. The expired form should still be used until replaced.
On a loan where the borrower enacted their rights under SCRA, how is interest paid by the borrower refunded? Is it Interest from time the Institution was notified, or time Borrower was to report? Is it a refund of any interest to the borrower or can the institution decide?
Interest is refunded from the effective date to report for active duty. §3937 (b)(2) LIMITATION EFFECTIVE AS OF DATE OF ORDER TO ACTIVE DUTY- Upon receipt of written notice and a copy of orders calling a servicemember to military service, the creditor shall treat the debt in accordance with subsection (a), effective as of the […]
How do we keep up to date with FinCEN Advisories and SAR Key Terms?
If you haven’t already, subscribe to FinCEN Notifications. FinCEN regularly releases updates, advisories, and guidance regarding SAR reporting and key terms. Subscribing to their email list or checking their website frequently helps ensure you stay informed of changes, especially regarding emerging threats like fraud schemes, money laundering, or cybercrime. The link to register can be […]
Can a customer be held liable for $500 of a fraudulent transaction that occurred more than two business days after the loss of a mobile phone if the debit card number is saved to a mobile application?
The Reg E definition of an access device is a generic “card, code, or other means of accessing an account” so the debit card number does meet the definition of an access device. However, for the $500 liability tier to apply, 1005.2(b)(2) notes that the fraud must involve an “accepted access device” which must be […]
