David Mulkerin

Juneteenth freedom day

A New Federal Holiday and an Old Federal Holiday – Alleviate The Confusion

So, if this article looks familiar, that’s because we sent out a similar version in the past two years and there is still some confusion as some institutions are open and some are closed. On June 17, 2021, the US got its first national holiday in 38 years. June 19 has been designated as “Juneteenth […]

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overdraft image with charts

FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion

The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating

FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion Read More »

community reinvestment act

April 1st is Fast Approaching: Did You Update Your CRA Public File?

April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update. Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your

April 1st is Fast Approaching: Did You Update Your CRA Public File? Read More »

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HMDA News and Census Tract Updates

Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated

HMDA News and Census Tract Updates Read More »

community reinvestment act

CRA Asset-size Thresholds Announced for 2023

The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million.

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mortgage loan disclosure

HMDA and HPML Thresholds Bumped Up for 2023

On December 28, 2022, the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price

HMDA and HPML Thresholds Bumped Up for 2023 Read More »

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