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It’s a Sign! (That’s Been Removed)
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. […]
Understanding REMA
A common acronym being discussed more and more in fair lending circles is REMA. The goal of this article is to establish a better understanding of what REMA is and how it can impact your bank. REMA is defined as the Reasonable Expected Market Area, which is the geographical area the regulatory agency believes a […]
2019 Regulation E Claim Calendar
These days, losses from Regulation E error claims are accepted by many institutions as the cost of doing business. Many institutions are relying more heavily upon internal and/or third-party fraud detection and prevention resources. But as you know, managing risk of loss is just part of the story. Regulation E compliance and financial risk continues […]
Cybersecurity: A Quick Overview in 5 Easy Steps
Part 1 of a 6-Part Series Network security, once thought of as an IT issue, is now Cybersecurity. A name change was necessary to keep up with the times, but no matter what it is called, is it still just an IT issue? We don’t think so. A shift in thinking and a different perspective […]
Final Rules Released for Acceptance of Private Flood Insurance
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 […]
Government Shutdown Financial Assistance
The government shutdown has ended for now, which is a relief to thousands of government workers. However, with another shutdown looming, many banks have asked in this period of uncertainty: How can we help affected individuals? Since we cannot predict the future, we thought the following would provide some ideas. The regulatory agencies have provided […]
HMDA and HPML Thresholds Bumped Up for 2019
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 […]
Important Update National Flood Insurance Program—What’s Going On?
On December 21, 2018, the President signed legislation that extended the National Flood Insurance Program’s (NFIP’s) authorization to May 31, 2019. All was well for another six months, or so everyone (including Congress) thought. On December 27th, FEMA ruled that the NFIP extension doesn’t allow for its continuation during the ongoing government shutdown. This decision […]
CRA Asset-size Thresholds Announced for 2019
The annual CRA asset-size thresholds for covered financial institutions were announced on December 20, 2018 applicable for 2019. 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. As a result of the 2.59% increase in the CPI, the […]
Will National Flood Insurance Program Expire?
On November 20, 2018, FEMA posted a press release reminding interested parties that the National Flood Insurance program (NFIP) expires at 11:59 p.m. on November 30, 2018. While FEMA is confident Washington will vote to reauthorize the NFIP, if a lapse were to occur, it would not impact policies already in effect. We will continue […]
