News & Analysis as of

Orrick's Financial Industry Week in Review - April 14, 2014

Agencies Apply Increased Leverage Ratio to Large U.S. Banks - On April 8, the Fed, FDIC and OCC adopted the final rule to increase the leverage ratio for the largest U.S. banks. The final rule applies to U.S. bank...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

California Proposes Rule To Clarify Scope Of Licensing Exemption

Earlier this month, the California Department of Business Oversight (DBO) issued a notice and request for comment on a proposed amendment to regulations that implement the California Finance Lenders Law (CFLL) and the...more

Congresswoman Urges OCC to Scrutinize Mortgage Servicing Rights Sales to Nonbank Servicers

Congresswoman Maxine Waters, who serves as the ranking member on the House of Representatives Committee on Financial Services, sent a letter to the Office of the Comptroller of the Currency and the Office of Mortgage...more

Mortgage Banking Takes Center Stage At OCC

On February 7, 2014, the Office of the Comptroller of the Currency (OCC) published a 232-page Mortgage Banking component to the Comptroller’s Handbook, its primary source of guidance for national banks and federal savings...more

OCC Issues Update to Mortgage Banking Booklet

The OCC issued an update to its Mortgage Banking booklet of the Comptroller’s Handbook, which was last updated in March 1996. The Mortgage Banking booklet generally provides guidance for bank examiners and bankers regarding...more

OCC Issues Revised Mortgage Banking Booklet

The Office of the Comptroller of the Currency (the “OCC”) issued an update to its Mortgage Banking booklet of the Comptroller’s Handbook, which was last updated in March 1996. The Mortgage Banking booklet generally provides...more

Banking Agencies Publish Supplemental Final Rules on Dodd-Frank Requirements for Appraisals for Higher-Risk Mortgage Loans

On Thursday, December 26, 2013, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, National Credit Union Administration, Bureau of Consumer Financial Protection (the “Bureau”),...more

Federal Banking Agencies Issue Interagency Statement on Supervisory Approach to Qualified Mortgage Loans

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

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 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

Orrick's Financial Industry Week in Review - December 16, 2013

Final Rules Implementing the Volcker Rule - On December 10, the Fed, CFTC, FDIC, OCC and SEC issued final rules to implement Section 619 of the Dodd-Frank Act (the Volcker Rule), which prohibit insured depository...more

Financial Services Law -- Dec 09, 2013

#Badidea: JPMorgan Chase Stumbles on Twitter - JPMorgan Chase’s recent activity on Twitter provides an example of the need for financial institutions to use caution when using social media....more

Risk Retention Follies - Part Deux

Well, Halloween has come and gone and with the annual bacchanal of faux frisson over zombies, vampires and the like behind us, can we also put away risk retention anxieties like one of those annoying and morally disturbing...more

Banking Agencies Clarify Guidance On Troubled Debt Restructurings

Last week, the Federal Reserve Board, the FDIC, the NCUA, and the OCC released interagency guidance related to the accounting treatment and regulatory credit risk grade or classification of commercial and residential real...more

Orrick's Financial Industry Week in Review - November 4, 2013

The Fed Approves New Fee Schedules - On October 31, the Fed announced new fee schedules, effective January 2, 2014, for payment services the Federal Reserve Banks provide to depository institutions (priced services). ...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

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

OCC Lending Handbook Needs Parenting on Important Legal Topics

In an earlier posting, I reviewed the OCC’s new Commercial Real Estate Lending handbook . The purpose of the handbook is to give parenting – I mean guidance – on risks inherent in commercial real estate lending. On legal...more

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