David Mulkerin

It’s that time again. The NMLS 2019 Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their NMLS […]

On October 10, 2019, the CFPB released a final rule (not yet published in the Federal Register) extending the current 500 open-end credit threshold until January 1, 2022. This new rule is effective on January 1, 2020. In addition to the rule above, the Bureau has issued an Executive Summary and an “unofficial, informal” redline

Get ready to update those policies and procedures! On September 27, 2019, the OCC, FDIC and FRB, in concurrence with the CFPB, published a revision to the appraisal rules at 12 CFR 34, 225 and 323 increasing the threshold amount where a residential real estate transaction requires a state-licensed, certified appraiser from $250,000 to $400,000.

Well, the CFPB is well on the way! On September 25, 2019, they released the 2020 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides timing and changing references of “2019” to “2020,” the changes appear to be items like updated descriptions and instructions for certain fields and revisions

The CFPB has released the public disclosures for HMDA data submitted for calendar year 2018. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can

Based on the 1.9% increase in the Consumer Price Index in effect on June 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2020. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. (1026.6(b)(2)(iii) and

You may recall a 2017 article discussing the long-awaited Regulation CC changes which, after reading, we found out were not the changes compliance professionals were waiting for. Well, wait no longer! Like St. Louis Blues fans, the day you’ve been waiting for has arrived! OK, that’s a lot of excitement for Regulation CC, but it

On Monday, March 18, 2019, the FDIC joined the other prudential regulators in removing the requirement to make available the Annual Disclosure Statement required under 12 CFR 350, to simplify their regulation as the information is available through the FDIC’s website. The OCC and FRB had previously removed this requirement in 2017 and 1998, respectively.

Back in 2012, the Bigger-Waters Act required implementation of rules regarding standards for acceptance of flood insurance policies by non-NFIP insurers, commonly referred to as private flood insurance. In October 2013, the regulators published a proposed rule. On January 28, 2019, the FDIC was the first regulator to release the joint rulemaking but we expect

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 due to the annual percentage increase in the Consumer Price Index for Urban Wage