Special Release

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Mitigate Risk: Understand Your Lending Patterns

Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan

Mitigate Risk: Understand Your Lending Patterns Read More »

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HMDA and HPML Thresholds Bumped Up for 2024

On December 18, 2023, 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 2024 Read More »

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024

On November 13, 2023, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections

HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024 Read More »

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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 »

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