Nutter Bank Report: September 2019

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  1. FDIC Adopts Final Rule Establishing Community Bank Leverage Ratio Framework
  2. OCC Issues Compliance Guidance on Registered Appraisal Management Companies
  3. CFPB Announces New Policies to Promote Innovation in Consumer Financial Services
  4. House Approves Bill to Provide Safe Harbor for Banks that Service Marijuana Businesses
  5. Other Developments: Examination Surveys and Deposit Insurance Applications

1. FDIC Adopts Final Rule Establishing Community Bank Leverage Ratio Framework

The FDIC has issued a final rule that introduces an optional, simplified measure of capital adequacy for qualifying community banking organizations known as the “community bank leverage ratio” or CBLR. According to the FDIC, the CBLR framework released on September 17 is designed to reduce regulatory reporting burden by removing the requirements for calculating and reporting risk-based capital ratios for qualifying community banking organizations that opt into the framework. To qualify for the CBLR framework, a community banking organization must have a tier 1 leverage ratio that is more than 9%, less than $10 billion in total consolidated assets, and limited amounts of off-balance-sheet exposures and trading assets and liabilities. A qualifying community banking organization that opts into the CBLR framework and continues to maintain a tier 1 leverage ratio of more than 9% will be considered to have satisfied the risk-based and leverage capital requirements in the generally applicable capital rule and will be considered to have met the well-capitalized ratio requirements under the Prompt Corrective Action regulations. Such a qualifying community banking organization will not be required to report or calculate risk-based capital. The final rule becomes effective on January 1, 2020, provided that it is also adopted by the OCC and the Federal Reserve as expected. The CBLR framework will be available for banks to use in their March 31, 2020 Call Reports. Click here for a copy of the final rule.

Nutter Notes: The final rule includes a two-quarter grace period during which a qualifying community banking organization that temporarily fails to meet the qualifying criteria, including the greater than 9% leverage ratio requirement, generally would still be deemed well-capitalized so long as the banking organization maintains a leverage ratio greater than 8%. At the end of the grace period, the banking organization must meet all qualifying criteria to remain in the community bank leverage ratio framework or otherwise must opt out of the CBLR framework. The FDIC also issued a final rule on September 17 that permits non-advanced approaches banking organizations to use the simpler regulatory capital requirements for mortgage-servicing assets, certain deferred tax assets arising from temporary differences, investments in the capital of unconsolidated financial institutions, and minority interest when measuring their tier 1 capital as of January 1, 2020. Finally, the FDIC issued another final rule on the same day that makes technical changes to incorporate the CBLR framework into the deposit insurance assessment system. A bank that uses the CBLR framework will not have any changes in how its assessment rate is calculated.

2. OCC Issues Compliance Guidance on Registered Appraisal Management Companies

The OCC has published new guidance to remind national banks and federal savings associations of the new registration requirement for appraisal management companies (“AMCs”) that became effective on August 10, 2019. The OCC’s guidance issued on September 16 explains that, under Section 1473 of the Dodd–Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and its implementing regulations, an AMC may not provide appraisal management services to a bank for most consumer credit transactions secured by a consumer’s principal dwelling if the AMC is not registered in the state or states in which it does business unless the AMC is subject to oversight by a federal financial institutions regulatory agency (i.e., the AMC is owned and controlled by a federally regulated depository institution). The guidance also recommends third-party risk management considerations for banks applicable to their relationships with AMCs. For example, the guidance recommends that bank management conduct sufficient due diligence to confirm that an AMC appropriately identifies transactions requiring a state certified or licensed appraiser if the bank relies on the AMC to determine whether a state certified or licensed appraiser is required for each transaction. The guidance also explains that, when no registered AMC is available, a bank may use an individual appraiser, a staff appraiser employed by the bank, a smaller AMC that has a panel with fewer than 15 appraisers in any state and fewer than 25 appraisers nationally in a given year (and is therefore not subject to the registration requirements), or a federally regulated AMC. Click here for a copy of the OCC’s guidance on registered AMCs.

Nutter Notes: Under Section 1473 of the Dodd–Frank Act, states are not required to establish an AMC registration and supervision program. In a state that does not have an AMC registration and supervision program, AMCs are prohibited from providing appraisal management services for most real-estate related financial transactions involving a federally regulated depository institution. However, the AMC registration requirement does not apply to an AMC that oversees a panel of 15 or fewer appraisers in a single state and fewer than 25 appraisers nationally in a given year. An AMC that is owned and controlled by an insured depository institution and regulated by the OCC, Federal Reserve, or FDIC is not subject to the registration requirement. The OCC’s guidance advises that several states may not offer the electronic capability to verify the registration status of AMCs. In these cases, the OCC recommends that bank management request evidence of registration directly from the AMC. In addition, the Appraisal Subcommittee (ASC) of the FFIEC is required to maintain an AMC national registry that includes AMCs that are registered with and subject to supervision by a state appraiser certifying and licensing agency or are federally regulated. According to the OCC’s guidance, an AMC that is listed on the ASC’s national AMC registry can be presumed to have met the AMC registration requirement.

3. CFPB Announces New Policies to Promote Innovation in Consumer Financial Services

The CFPB has released three new policies related to innovation and regulatory compliance: a revised No-Action Letter (NAL) Policy, Trial Disclosure Program (TDP) Policy, and Compliance Assistance Sandbox (CAS) Policy. The revised NAL policy issued on September 10 makes a number of changes to the CFPB’s 2016 NAL Policy to include, among other things, a more streamlined review process focusing on the consumer benefits and risks of the product or service in question. The new TDP Policy issued on September 10 allows banks and other consumer financial services providers seeking to improve consumer disclosures to conduct in-market testing of alternative disclosures for a limited time with the permission of the CFPB. The CAS Policy issued on September 10 enables testing of a new financial product or service where there is uncertainty about the permissibility of the product or service. Under the CAS policy, a consumer financial services provider may apply to the CFPB for a safe harbor from certain consumer protection liability for specified conduct during a testing period. The CFPB will evaluate the product or service for compliance with relevant law. If approved, an applicant that complies in good faith with the terms of the approval may receive protection from liability under the Truth in Lending Act, the Electronic Fund Transfer Act, and the Equal Credit Opportunity Act with respect to the new financial product or service during the testing period. Click here for a copy of the revised NAL Policy, click here for a copy of the TDP Policy, and click here for a copy of the CAS Policy.

Nutter Notes: On September 10, the CFPB also announced the launch of the American Consumer Financial Innovation Network (“ACFIN”) to enhance coordination among federal and state regulators in facilitating financial innovation. The CFPB said that it has invited all state regulators to join ACFIN. The initial members of ACFIN are the Attorneys General of Alabama, Arizona, Georgia, Indiana, South Carolina, Tennessee, and Utah. According to the ACFIN charter, its objectives include coordination among members to benefit consumers by facilitating innovation that enhances competition, consumer access, or financial inclusion. The ACFIN also seeks to minimize unnecessary regulatory burdens, bolster regulatory certainty for innovative consumer financial products and services, and help ensure that markets for consumer financial products and services are free from fraud, discrimination, and deceptive practices. To accomplish these objectives, the ACFIN charter provides that members will cooperate with each other through, among other things, coordinating innovation-related policies, procedures, and activities, with the opportunity to also coordinate on no-action letters or sandbox trials. The ACFIN charter also contemplates that members will share information related to innovation in markets for consumer financial products and services, including technical expertise, market intelligence, and best practices.

4. House Approves Bill to Provide Safe Harbor for Banks that Service Marijuana Businesses

The U.S. House of Representatives voted to approve H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking Act of 2019 with bipartisan support by a vote of 321-103. The bill approved by the House on September 25, if it became law, would create protections for depository institutions that provide financial services to a “cannabis-related legitimate business” operating in compliance with applicable state laws. The Senate is expected to consider a similar measure. The bill defines “cannabis-related legitimate business” to include a manufacturer, producer, or other person or company that participates in the cultivation, production, manufacture, sale, transport, display, dispensing, distribution, or purchase of marijuana or marijuana products pursuant to state law. The bill would prevent any federal banking agency from prohibiting a depository institution (or its service providers) from, or penalizing a depository institution (or its service providers) for, providing a financial service to a marijuana business or a service provider of a marijuana business that operates in compliance with state law. The bill is supported by the major national banking and credit union trade associations and a group of 50 state bankers associations. Click here for a copy of the current text of the bill.

Nutter Notes: The SAFE Banking Act of 2019 was introduced by Representative Ed Perlmutter of Colorado and is co-sponsored by over 200 representatives from both parties. The bill would not affect the status of cannabis or marijuana as an illegal substance under the Federal Controlled Substances Act. Therefore, even if the bill becomes law, the cultivation, distribution, and possession of marijuana would remain criminal under federal law, and all proceeds of such activities would remain illicit funds under federal law. The bill would amend the Bank Secrecy Act to require FinCEN to issue guidance on suspicious activity reporting (“SAR”) related to a cannabis-related legitimate business or service provider. The bill would require that any such SAR must comply with the guidance, and that the guidance be consistent with the purpose and intent of the SAFE Banking Act of 2019 to “not significantly inhibit the provision of financial services to a cannabis-related legitimate business or service provider in” a state or other political subdivision of the U.S. in which marijuana-related business has been legalized.

5. Other Developments: Examination Surveys and Deposit Insurance Applications

  • FDIC Office of the Ombudsman Will Take Over Post-Examination Surveys

The FDIC announced on September 19 that the Office of the Ombudsman will now be administering the post-examination survey process. The Ombudsman is independent of the supervisory process, reports directly to the FDIC Chairman’s office, and is a confidential resource for banks. The FDIC said that the change is meant to ensure confidentiality of survey responses, promote additional candid feedback, and improve response rates.

Nutter Notes: The Ombudsman will assume responsibility for soliciting post-examination survey responses effective October 1, 2019. The Ombudsman will send notice that the survey will accompany a Report of Examination and will provide reminders to encourage participation in the survey. The Ombudsman will also serve as the contact point for banks regarding the survey and follow-up requests. Click here for a copy of the FDIC’s announcement and a copy of the current survey questions for each exam type.

  • FDIC Issues Guidance on Applications for Deposit Insurance

The FDIC issued guidance in the form of supplemental questions and answers (“Supplemental Q&As”) to help organizing groups develop applications for deposit insurance. The Supplemental Q&As note that applications for deposit insurance do not need to identify a specific physical location (i.e., an address) for the proposed institution’s main office at the time of submission. The Supplemental Q&As also clarify that, while the proposed chief executive officer is to be identified at the time of filing, other senior executive officers may be identified later in the process.

Nutter Notes: The new Supplemental Q&As supplement the FDIC’s Statement of Policy on Applications for Deposit Insurance, issued in 1998. For organizing groups that have not yet identified the specific address of the main office at the time of filing, the Supplemental Q&As instruct the applicants to reasonably describe the anticipated physical location so that the FDIC and other interested parties can understand the general location and geographic market of the proposed institution. Click here for a copy of the Supplemental Q&As.

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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