David Mulkerin

flood-insurance-policy

In a Government Shutdown the National Flood Insurance Program Could be Affected

So, the Government may shut down. Again. This has happened before and will likely happen again. When this happens, one of the many “non-essential” services and programs is the National Flood Insurance Program (NFIP). So, what do we do if/when a shutdown happens? If there is a disruption to the NFIP, we should be prepared

In a Government Shutdown the National Flood Insurance Program Could be Affected Read More »

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New Threshold Amounts for 2024 under Regulation Z CARD Act, HOEPA and QM Sections

Based on the 4.6% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2023, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2024. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 4.9% increase

New Threshold Amounts for 2024 under Regulation Z CARD Act, HOEPA and QM Sections Read More »

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

A New Federal Holiday and an Old Federal Holiday – Alleviate The Confusion Read More »

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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