News & Analysis as of

FFIEC Issues Joint Statements on DDoS Cyber-Attacks and Cyber-Attacks on ATM and Card Authorization Systems

On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more

Federal Regulators Issue Proposal on Minimum Requirements for Appraisal Management Companies

Collectively, the FDIC, the OCC, FRB, CFPB, NCUA and FHFA issued a proposed rule establishing the minimum requirements for mortgage appraisal management companies. An appraisal management company is generally an entity that...more

Federal Regulators Amend Appraisal Requirements for Higher-Priced Mortgages

Collectively, the FDIC, the OCC, FRB, CFPB, NCUA, FHFA and HUD finalized the rule governing appraisal requirements for higher-priced mortgage loans. In August 2013, the federal regulators issued a proposal to amend Regulation...more

Agencies Finalize Exemptions To Higher-Priced Mortgage Loan Appraisal Requirements

On December 12, the Federal Reserve Board, the CFPB, the FDIC, the FHFA, the NCUA, and the OCC, issued a final rule supplementing their January 2013 interagency appraisal rule. As described in detail in our Special Alert, the...more

Prudential Regulators Address Impact Of QM Lending On CRA Ratings

On December 13, the Federal Reserve Board, the FDIC, the OCC, and the NCUA issued an interagency statement to clarify safety and soundness expectations and CRA considerations in light of the CFPB’s ability-to-repay/qualified...more

Financial Services Bulletin: Action At Federal Agencies

Agencies Adopt Final Rules Exempting Certain Higher-Price Mortgage Loans from Appraisal Requirements - On Thursday, December 12, 2013, the Federal Reserve Board, the Consumer Financial Protection Bureau, the Federal...more

FFIEC Social Media Guidance Addresses "Reputational Risks" from Social Media

Financial Institutions Should Develop Policies and Practices to Address and Monitor Reputational and Operational Risks - On December 10, 2013, the Federal Financial Institutions Examination Council (FFIEC) issued its...more

Prudential Regulators Clarify Supervisory Approach Relative to CFPB Mortgage Regulation

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

Supervisory Approach for Qualified and non-Qualified Mortgage Loans

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

Social Media: Consumer Compliance Risk Management Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to...more

Financial Regulatory Agencies Issue Proposed Joint Diversity Policy, as Required under Dodd-Frank

On Friday, October 25, 2013, the Bureau of Consumer Financial Protection, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the...more

Financial Regulators Propose Framework For Assessing Diversity At Financial Firms

On October 23, the CFPB, the OCC, the FDIC, the Federal Reserve Board, the NCUA, and the SEC proposed joint standards for assessing the diversity policies and practices of regulated institutions. Section 342 of the Dodd-Frank...more

Agencies Issue Guidance on Troubled Debt Restructurings

The four federal financial institution regulatory agencies—the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the...more

FRB, FDIC, OCC AND NCUA Issue Joint Supervisory Guidance Concerning Troubled Debt Restructurings

The FRB, FDIC, OCC and NCUA (collectively, the “Agencies”) jointly issued guidance to financial institutions entitled InterAgency Supervisory Guidance Addressing Certain Issues Related to Troubled Debt Restructurings (the...more

Federal Regulators Issue Statement on Fair Lending Compliance and the Ability-to-Repay and Qualified Mortgage Rules

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

Interagency Fair Lending Guidance: A First Step, but in the Right Direction?

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

Joint Release on QM Fair Lending Risks

On October 22, the Fed, CFPB, FDIC, NCUA and OCC issued a joint statement to address industry questions on fair lending risks associated with offering only qualified mortgages....more

CFPB proposes standards for assessing diversity policies of regulated entities

The CFPB and five other federal agencies have proposed joint standards for assessing the diversity policies and practices of regulated entities relating to employment and contracting with third parties. The proposal was...more

Orrick's Financial Industry Week in Review - October 28, 2013

Joint Release on QM Fair Lending Risks - On October 22, the Fed, CFPB, FDIC, NCUA and OCC issued a joint statement to address industry questions on fair lending risks associated with offering only qualified mortgages. ...more

CFPB joins interagency statement on qualified mortgage fair lending risks

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

Special Alert: Agencies Issue Joint Statement On Fair Lending Compliance And The CFPB’s ATR/QM Rule

On October 22, the CFPB, the OCC, the FDIC, the Federal Reserve Board, and the NCUA (collectively, the Agencies) issued a joint statement (Interagency Statement) in response to inquiries from creditors concerning their...more

Amendments Proposed To Federal Flood Insurance Regulations

Federal banking agencies have issued a joint notice of proposed rulemaking to implement certain provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (the “Act”). The proposed rule will amend each agency’s flood...more

Federal financial regulatory agencies propose appraisal requirement exemptions for certain higher-priced mortgage loans

The CFPB, Federal Reserve Board, FDIC, FHFA, NCUA, and OCC published in the Federal Register on August 8, 2013 proposed rules creating several exemptions to the appraisal requirements for higher-priced mortgage loans....more

Financial Services Bulletin: Action at the FRB, CFPB and OCC

Agencies Propose Rule Exempting Certain Mortgages from Appraisal Requirements - On Wednesday, July 10, 2013, the Board of Governors of the Federal Reserve System (the “Fed”), Bureau of Consumer Financial Protection,...more

Infobytes - A Weekly In-depth review of news & developments in the financial services industry - April 5, 2013

In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - MISCELLANY - FIRM NEWS - MORTGAGES - BANKING - CONSUMER FINANCE - SECURITIES - PAYMENTS - Excerpt from Payments: CFPB...more

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