Episode 25: 10 Factors That May Hinder a Contractor’s Ability to Repay Its Bank Loans and Threaten Its Existence
Critical Mortgage Regulatory Updates by the Consumer Financial Protection Bureau for 2013 and 2014
On Wednesday, February 5, the House Financial Services Committee will hold the first part of a two-part hearing on “rent-a-bank” structures. The hearing is titled “Rent-A-Bank Schemes and New Debt Traps: Assessing Efforts to...more
The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more
1. FDIC Proposes Changes to Deposit Insurance Assessment Rule for CBLR Banks The FDIC has published a proposal that describes how the agency would apply the Community Bank Leverage Ratio (“CBLR”) framework previously...more
A group of 13 state attorneys general and the District of Columbia AG have sent a letter to the FDIC commenting on the agency’s request for information on small-dollar lending. ...more
Hours after the CFPB released its final payday/auto title/high-rate installment loan rule on October 5, 2017, the OCC rescinded its guidance on deposit advance products. ...more
Editor's Note - Friend the Fed! As is the case every August, our federal government and regulators are hard at work, laser focused on the important issues of the day. In this regard, on August 18, the Federal Reserve...more
The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule. The CFPB has issued a proposal to postpone the TRID rule’s effective date from...more
The FDIC, OCC, NCUA and FRB issued an interagency statement on the supervisory approach to originating qualified mortgages under the CFPB’s ability-to-repay and qualified mortgage rule finalized in January 2013 and...more
The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Prudential Regulators”) have...more
On December 13, Fed, FDIC, NCUA and OCC issued a statement to clarify safety-and-soundness expectations in order to guide institutions engaged in residential mortgage lending as they assess the implementation of the CFPB’s...more
FDIC Cautions Financial Institutions About D&O Insurance - Noting a rise in the use of exclusions in insurance policies for executives at financial institutions, the Federal Deposit Insurance Corporation urged banks to...more
In response to inquiries from creditors about liability under the Equal Credit Opportunity Act’s disparate impact doctrine on originating qualified mortgages under the CFPB’s ability-to-repay provisions, the CFPB, OCC, FRB,...more
Five federal regulators, with HUD noticeably absent, issued the first interagency guidance on the much-debated intersection of fair lending enforcement and the Ability-to-Repay and Qualified Mortgage Standards Rule taking...more
The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more
Federal regulators have issued an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the Consumer Financial Protection Bureau’s...more
On April 25 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) proposed for public comment supervisory guidance to institutions subject to their jurisdictions (i.e.,...more
The FDIC has scheduled the following three free teleconferences on the CFPB’s new mortgage-related rules for officers and employees of FDIC-supervised institutions... ...more
In This Issue: - Financial Industry Developments •CFPB Rules on Ability-to-Repay and Qualified Mortgages •Independent Foreclosure Review Settlement •CFPB Final Rules on High-Cost Mortgages •Rating Agency...more