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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 made regarding the agencies’ appraisal regulations and guidance. According to the agencies, these FAQs do not introduce new policy or guidance but assemble previously communicated policy and interpretations.

Twenty-three FAQs focus on, and should be utilized along with, the agencies’ appraisal regulations issued under Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (Title XI), the real estate lending standards, the December 2010 Interagency Appraisal and Evaluation Guidelines (Valuation Guidelines), and the March 2016 Interagency Advisory on the Use of Evaluations in Real Estate-Related Financial Transactions (Evaluations Advisory).

These new FAQs incorporate some of the questions issued by the agencies in 2005 (see questions 14 through 23) and supersede the 2005 FAQs.

The FAQs are broken out into topics including Appraisal and Evaluation Programs, Appraisal Exemptions, Appraisals and Evaluations, and Independence.

Here is a link to the FAQs on the FDIC’s website.

As we were reminded by a recent statement about supervisory guidance from the regulators, these FAQs are not a rule or regulation, but additional guidance to help lenders comply with the rule.

Ready for HMDA 2019?

Well, the CFPB is well on the way! On October 23, 2018 they released the 2019 HMDA Filing Instructions Guide (FIG) for data collected in 2019 and reported in 2020. Besides timing and changing references of “2018” to “2019,” the changes appear to be items like updated descriptions and instructions for certain fields and revisions to certain edits.

We’re sure there will be more changes to come from lessons learned during the 2018 filing. Speaking of the 2018 filing, the 2018 FIG was updated shortly after the revised HMDA rule went into effect, and then again with a technical fix in September.

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