Have you heard about the new registration requirements for Appraisal Management Companies? Effective August 10, 2019 all appraisal management companies (AMC) must register with the state or states in which they perform business and are subject to state supervision, if …
Appraisal Management Company Registration: Are You Aware? Evelyn I. Dehmey
Are your polices updated for the new thresholds for appraisals on Residential Real Estate loans? The Appraisal Rule was collectively amended by FDIC, Federal Reserve, and OCC. The threshold for requiring an appraisal on residential real estate transactions (secured by …
We get questions from time to time as to whether a bank can target the geographic area around a branch, such as during a branch opening, or do a prescreened mailing to a group of people with particular characteristics. Of …
EGRRCPA – Let’s Take Stock! The “Economic Growth, Regulatory Relief, and Consumer Protection Act” was signed into law on May 24, 2018. It had many moving parts, some effective upon passage and others where regulations were first needed. Let’s explore …
On January 2, 2019, Kathleen Kraninger of the CFPB entered her first Consent Order with USAA Federal Savings Bank, an $80 billion institution based in San Antonio, TX. USAA had Regulation E violations related to: Failing to properly stop preauthorized …
Evelyn I. Dehmey What Can We Learn from the USAA Regulation E Case?
HMDA Small Reporter Overview With the new year comes HMDA reporting. Let’s take a look at the partial relief that EGRRCPA provided to some financial institutions. On May 24, 2018, the President signed the Economic Growth, Regulatory Relief, and Consumer …
CBD Oil Product Retailers – What’s the Buzz? Have you seen them yet – the neon signs, plastic banners, billboards, and pop-up ads flashing “We Sell CBD!”? Since the Farm Bill passed in December 2018, the sales signs are popping …
A Lookback at Some Compliance Happenings in 2018 With the new year just beginning, it is a good idea to review some of the compliance changes that occurred in 2018: The new HMDA rules became effective on January 1, 2018. …
A Lookback at Some Compliance Happenings in 2018 Shanin L. Bachstein
PREPAID ACCOUNTS RULE – DOES THIS AFFECT OUR BANK? The Prepaid Accounts Rule has been delayed so many times that Compliance Officers have almost forgotten about it. The initial final rule was first published on October 5, 2016, delayed on …
When is a Reg B “Notice of Action” Required Regulation B requirements are intended to protect the applicant(s) from discrimination. The regulation requires financial institutions to make timely credit decisions and give an applicant distinct reasons for a denied loan …
Kay M. Scarselli When is a Reg B “Notice of Action” Required