On October 30, 2020 the CFPB announced a final version of the Fair Debt Collection Practices Act. Although the rule is generally applicable to third-party debt collection practices, it has an indirect effect on financial institutions. First, at a pre-described …
Consumer financial services has been a hot topic in California and was recently solidified with the passage of AB-1864. This bill renames the current “Department of Business Oversight” as the “Department of Financial Protection and Innovation” (DFPI). The former authority …
On June 24, 2020 the FFIEC announced the availability of 2019 HMDA Disclosures. At the same time, they shared an analysis of the aggregate data submitted, comparing 2018 data with 2019 data. This helps us to understand how financial institutions …
How might HMDA Thresholds Affect Your Institution? On April 16, the CFPB announced its final rule on the thresholds for reporting closed-end and open-end loans for HMDA. The threshold for closed-end mortgage loans increased from 25 to 100 loans effective …
Evelyn I. Dehmey How might HMDA Thresholds Affect Your Institution
WHAT IS TIME-BARRED DEBT AND HOW DOES IT AFFECT MY BANK? On February 21, the CFPB announced a proposal to amend Regulation F – Fair Debt Collection Practices Act (FDCPA) by requiring debt collectors to make certain disclosures when collecting …
Evelyn I. Dehmey WHAT IS TIME-BARRED DEBT AND HOW DOES IT AFFECT MY BANK
DISTINGUISHING “ABUSIVE” PRACTICES Many leading articles on the subject of the CFPB’s release of its position on “abusive” acts or practices proclaim that the CFPB has defined “abusive.” This is simply not true. The Dodd Frank Act already defined “abusive” …
WHAT’S IN YOUR LOAN REVIEW? Whether you’re a small community bank or a large regional bank, you should have a credit risk review function to analyze individual loan quality and to provide analysis of your entire portfolio quality. On October …
CRA TRACKING FOR PANDEMIC LOANS While we’re in the throes of the Covid-19 pandemic, the one thing we don’t need is more work. But it is an important season to think about how loan programs and modifications can work to …
SAVINGS ACCOUNTS AREN’T SAVINGS ANYMORE? When the FRB lowered required reserve requirements for checking and savings accounts to zero percent on March 26, it set off a host of questions about how that action affected checking and savings account definitions. …
The ATM – Automated Teller Machine – made its debut in 1967 at Barclays Bank in London. The first American version became available in 1969 at Chemical Bank on Long Island, NY. Initially, access was restricted to customers of the …
Evelyn I. Dehmey Evolution of the ATM: WHAT WILL MY ATM DO NEXT?