CFPB Supervisory Highlights – Winter 2020… and how CSG can help

In February, the CFPB released its 21st Supervisory Highlights Report. This report covered findings identified in examinations conducted by the CFPB between April 2019 and August 2019. Areas included in the report include mortgage servicing, payday lending (including general Regulation Z requirements), debt collection, and student loan servicing. Mortgage Servicing Highlights Regulation X violations discussed in the report include failing … Read More

CFPB Extends the 500 open-end lines of credit threshold to January 1, 2022

On October 10, 2019, the CFPB announced that it issued a final rule extending the current temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to … Read More

Private Flood Insurance

Private Flood Insurance Requirements Effective July 1, 2019 The OCC, Federal Reserve, FDIC, FCA, and NCUA issued a joint final rule, effective July 1, 2019, requiring regulated institutions to accept certain private flood insurance policies in addition to the National Flood Insurance Program (NFIP) policies. A Private flood insurance is an insurance policy that: 1.  Is issued by an insurance … Read More

NMLS Renewal Period Opens

The annual NMLS renewal period for 2018 began on November 1, 2017, and ends Sunday, December 31, 2017. Individuals and businesses are encouraged to renew their licenses or registrations early, so there is no impact to their business in 2018.  The renewal information is available here. If the renewal process is not completed prior to December 31st, the MLO is placed in an … Read More

CFPB Beta Launch of HMDA Platform

From the CFPB – The Bureau is pleased to announce the beta launch of the new HMDA Platform. The main objective of the beta release is to provide financial institutions an opportunity to become familiar with the HMDA Platform and, in particular, determine whether their sample LAR data complies with the reporting requirements outlined in the Filing Instructions Guide for … Read More

Updated TRID Small Entity Compliance Guide

The CFPB released version 5.0 of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October 10, 2017.  Compliance with the amendments will be required for applications received on or after October 1, 2018. Updates to the Guide include: requirements and guidance on current requirements for tolerances in the good … Read More

CFPB HMDA Implementation Materials

The CFPB has updated their cart Collection and Reporting of HMDA Information about Ethnicity and Race.  Additionally, the CFPB has published a new chart, Reportable HMDA Data: A Regulatory and Reporting Overview Reference (“Reporting Reference Chart”) intended to be used as a reference for data points required to be collected, recorded, and reported under Regulation C. The Reporting Reference Chart … Read More

FDIC Releases Interagency Designated Key HMDA Data Fields List

From FIL-51-2017: Summary: The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are issuing designated key Home Mortgage Disclosure Act (HMDA) data fields to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s requirements. Statement of Applicability to Institutions With … Read More

OCC Bulletin 2017-28

Risk Management Guidance for Higher-Loan-to-Value Lending Programs in Communities Targeted for Revitalization The OCC issued Bulletin 2017-28 regarding circumstances under which banks may establish a program to originate certain higher-LTV loans, and OCC’s supervisory considerations regarding such programs.  These programs may be eligible for Community Reinvestment Act credit. The guidance provides information about the required policies and procedures under such … Read More

HMDA Examiner Testing Guidelines

The FFIEC released its HMDA Examiner Transaction Testing Guidelines for institutions that report HMDA data.  The Guidelines will apply to examination of HMDA data collected beginning in 2018 and reported beginning in 2019. From the CFPB: The Guidelines will help ensure accurate data and address reporting burden concerns When examining financial institutions, federal supervisory agencies with HMDA supervisory authority may … Read More