Interim Final Rule Regarding Inflation-Adjusted Civil Money Penalties

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On July 1, 2016, the Office of the Comptroller of the Currency (OCC) published an interim final rule that amends its rules of practice for national banks and federal savings associations to adjust the maximum amount of each civil money penalty (“CMP”) within its jurisdiction.  The effective date of the rule is August 1, 2016, and the adjustments apply only to penalties assessed on or after such date.  The interim final rule includes revisions to charts that set forth the inflation-adjusted maximum CMPs and an addition of a new penalty that makes it unlawful for a creditor who extends credit or provides services for a consumer credit transaction secured by the consumer’s principal dwelling to engage in acts that violate the appraiser independence requirements, among other changes. Press Release. Interim Final Rule.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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