Nutter Bank Report November 2018

Nutter McClennen & Fish LLP


  1. Federal Banking Agencies Propose Alternative Capital Framework for Community Banks
  2. Court Rules that Overdraft Fee Class Action Lawsuit May Continue
  3. Agencies Plan to Increase the Threshold for Residential Real Estate Appraisal Exemption
  4. Federal Banking Agencies Propose to Expand Eligibility to Use Streamlined Call Reports
  5. Other Developments: Deposit Insurance Assessments and Inflation Adjustments

1. Federal Banking Agencies Propose Alternative Capital Framework for Community Banks

The federal banking agencies have proposed a new community bank leverage ratio (“CBLR”) framework that would simplify regulatory capital requirements for qualifying community banking organizations with less than $10 billion in total consolidated assets, as required by section 201 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (“EGRRCPA”). Under the proposal announced on November 21, a qualifying community banking organization that elects to use the CBLR framework would no longer be required to calculate or report the components of capital used in the calculation of risk-based capital ratios or the tier 1 leverage ratio, such as tier 1 capital, total capital, or risk-weighted assets. The CBLR framework would be available to a depository institution or a holding company with an initial CBLR of greater than 9% that is not an advanced approaches banking organization, has total consolidated assets of less than $10 billion, and that meets certain additional criteria, including total off-balance sheet exposures (subject to certain exclusions) of 25% or less of total consolidated assets and total trading assets and trading liabilities of 5% or less of total consolidated assets. Under the proposal, a qualifying community banking organization that elects to use the CBLR framework and maintains a CBLR of greater than 9% would not be subject to other risk-based and leverage capital requirements and would be considered to be well capitalized under the agencies’ prompt corrective action (“PCA”) rules. Public comments on the CBLR proposal will be due within 60 days after publication in the Federal Register, which is expected shortly. Click here for a copy of the CBLR proposal.

Nutter Notes: Once a qualifying community banking organization elects to use the CBLR framework, it would be considered well capitalized as long as its CBLR is more than 9%. Such a CBLR banking organization would be considered to have met the minimum capital requirements under its primary federal banking agency’s capital rule if its CBLR is at least 7.5%. If a CBLR banking organization’s CBLR deteriorates, it may choose to stop using the CBLR framework and instead become subject to the generally applicable risk-based capital requirements. However, if a CBLR banking organization’s CBLR falls below 9% and it wishes to continue using the CBLR framework, the proposal would establish CBLR levels to serve as proxies for the PCA capital categories. A CBLR of 7.5% or more would be treated as adequately capitalized, a CBLR of at least 6.0% but less than 7.5% would be treated as undercapitalized, and a CBLR of less than 6.0% would be treated as significantly undercapitalized. (The definition of critically undercapitalized would remain the same as under the PCA framework and the generally applicable capital requirements.) In addition, because the FDIC uses tier 1 capital and the tier 1 leverage ratio as part of its deposit insurance assessment system and CBLR banking organizations would no longer be required to report those measures, the FDIC plans to publish a separate proposal to address the application of the CBLR framework to the deposit insurance assessment system.

2. Court Rules that Overdraft Fee Class Action Lawsuit May Continue

A federal judge in Massachusetts recently ruled that a class action lawsuit brought by depositors against an insured depository institution to recover overdraft fees charged on the basis of “available balances” can proceed. The Massachusetts federal district court ruling issued on November 8 came in a case where the depository institution’s account agreement and overdraft opt-in agreement did not specify whether sufficiency of funds for overdrafts would be based on “available balance” or the ledger or “actual balance.”  The agreements stated only that a depositor could be charged for an overdraft in the event there is not “enough money” in an account to cover a transaction but the institution pays it anyway. The court ruled that there were sufficient facts in dispute about the ambiguity of the depository institution’s written agreements and disclosures about how overdrafts were calculated to allow the lawsuit to proceed for claims based on breach of contract and violations of Regulation E under the Electronic Fund Transfer Act (“EFTA”). In particular, the court ruled that the safe harbor provision in the EFTA which protects financial institutions from liability for certain disclosure failures if a model clause from Regulation E is used did not apply even though the depository institution used a model clause in its disclosures. Click here for a copy of the court’s ruling.

Nutter Notes: The depository institution in this case determined overdrafts on the basis of available balance, which is calculated by deducting pending debits and deposit holds. As a result, the available balance can be lower than the actual or ledger balance in an account. The court found that the overdraft opt-in agreement did not provide clarification that “enough money” meant the available balance, and held that “a reasonable person could construe ‘enough money’ to mean ‘ledger balance’.” According to the court’s ruling, the depository institution argued that its account agreement included references to available funds and overdrafts, including a provision stating that the institution was not obligated to make a payment that “would draw the available balance in the account below the minimum balance for the account,” and referenced overdrafts in the schedule of fees and charges. However, the court found that the agreement did not properly define the meaning of “available balance” and pointed out that the institution’s practice of subtracting pending transactions from the ledger balance to calculate available balance was not described in the institution’s funds availability policy. The court also criticized the portion of the account agreement pertaining to overdrafts and the overdraft opt-in agreement for failing to refer to the institution’s funds availability policy for an explanation of how a depositor’s balance is calculated for purposes of overdrafts.

3. Agencies Plan to Increase the Threshold for Residential Real Estate Appraisal Exemption

The FDIC and OCC have proposed to amend the agencies’ real estate appraisal regulations to raise the threshold – from $250,000 to $400,000 – at or below which appraisals would not be required for certain residential real estate-related transactions. The proposed amendments issued on November 20 would require that, for an exempt residential real estate transaction, the bank must obtain an evaluation of the mortgaged property that is consistent with safe and sound banking practices. The proposed amendments also would add to the agencies’ appraisal regulations the residential rural exemption enacted by the EGRRCPA to the categories of exempt real estate-related transactions and require that banks obtain an evaluation for exempt residential rural transactions. Finally, the proposed amendments would require banks to review appraisals for compliance with the Uniform Standards of Professional Appraisal Practice (“USPAP”), as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). The Federal Reserve is also considering the proposed amendments and, if approved, the amendments would be jointly proposed by the three federal banking agencies. Public comments on the proposed amendments will be due within 60 days after publication in the Federal Register, which would be shortly after Federal Reserve approval. Click here for a copy of the proposal.

Nutter Notes: The proposal to raise the threshold for exemption from appraisal requirements for residential transactions follows the federal banking agencies’ April 2018 decision to increase the threshold for commercial real estate transactions that require an appraisal from $250,000 to $500,000. Like the residential real estate exemption, the commercial exemption allows a bank to use an evaluation, rather than an appraisal, for commercial real estate transactions exempted by the $500,000 threshold. An evaluation under the agencies’ real estate appraisal regulations is an estimate of the market value of mortgaged property that is not prepared by a state certified or licensed appraiser and is not required to comply with USPAP. According to the Interagency Advisory on Use of Evaluations in Real Estate-Related Financial Transactions, the agencies expect such evaluations to be prepared by someone who is knowledgeable, competent, and independent of the transaction and the loan production function of the bank. The evaluation preparer may be an unaffiliated third party or a bank employee, according to the interagency advisory. An evaluation report, according to the interagency advisory, should describe the approach or methodology used to estimate the market value of the real property, and contain sufficient supporting information to allow a reader to understand the analysis and the bank’s decision to engage in the transaction.

4. Federal Banking Agencies Propose to Expand Eligibility to Use Streamlined Call Reports

The federal banking agencies have issued a proposal to streamline regulatory reporting for certain banks with total assets of less than $5 billion. The proposal announced on November 7 would expand eligibility to file the agencies’ most streamlined report of condition, the FFIEC 051 Call Report, to any “covered depository institution,” which generally would include a bank with less than $5 billion in total consolidated assets, with no foreign offices, and that is not required to or has not elected to calculate its risk-based capital requirements using the internal ratings-based and advanced measurement approaches under the agencies’ regulatory capital rules. A bank that qualifies as a large or highly complex institution for purposes of the FDIC’s assessment regulations would not qualify as a covered depository institution under the proposal. The proposal also would reduce the reporting items on the FFIEC 051 Call Report for the first and third calendar quarter reports each year. Public comments on the proposal are due by January 18, 2019. Click here for a copy of the proposal.

Nutter Notes: Only banks with no foreign offices and less than $1 billion in total assets are currently eligible to use the FFIEC 051 Call Report. The proposal would implement section 205 of the EGRRCPA, which requires the federal banking agencies to issue regulations that allow for certain banks with less than $5 billion in total consolidated assets to have reduced reporting requirements for the first and third quarterly Call Reports each year. The agencies estimate that the first and third quarterly FFIEC 051 Call Reports under the proposal would have 37% fewer reportable items. According to the agencies, the most significant areas of reduced reporting in the first and third quarterly Call Reports for covered depository institutions would include data items related to categories of risk-weighting of various types of assets and other exposures under the agencies’ regulatory capital rules, fiduciary and related services assets and income, and troubled debt restructurings by loan category.

5. Other Developments: Deposit Insurance Assessments and Inflation Adjustments

  • FDIC Announces Deposit Insurance Assessment Relief as Key Ratio Reached

The FDIC announced on November 28 that the Deposit Insurance Fund Reserve Ratio reached 1.36% as of September 30, 2018, which exceeds the required minimum reserve ratio of 1.35% under the Dodd-Frank Act. As a result, surcharges on insured banks with total consolidated assets of $10 billion or more will cease and small banks will receive assessment credits for the portion of their assessments that contributed to the growth in the reserve ratio from between 1.15% and 1.35%, which will be applied when the reserve ratio is at or above 1.38%.

Nutter Notes: According to the FDIC, the aggregate amount of credits to small banks will be approximately $750 million. The FDIC said that it will notify each small bank of its individual credit amount in January 2019. Click here for a copy of the FDIC’s announcement.

  • Fed and CFPB Announce Truth in Lending Inflation Adjustments

The Federal Reserve and CFPB announced on November 21 the inflation adjustments to the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) that will apply for determining exempt consumer credit and lease transactions in 2019. As a result of the adjustments, Regulation Z and Regulation M generally will apply to consumer credit transactions and consumer leases of $57,200 or less in 2019 (private education loans and mortgage loans are subject to Regulation Z regardless of the amount of the loan).

Nutter Notes: The agencies on November 20 jointly proposed amendments to Regulation CC (Availability of Funds and Collection of Checks) that would adjust for inflation the amount of funds banks must make available to their customers. Public comments on the proposed amendments will be due within 60 days after publication in the Federal Register, which is expected shortly. Click here for a copy of the amendments to Regulation M, here for a copy of the amendments to Regulation Z, and here for a copy of the proposed amendments to Regulation CC.

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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