We first posted an article about proposed amendments to the Military Lending Act (MLA) on December 30, 2014. Ultimately, the Department of Defense (DoD) amended its regulation effective October 1, 2015, and extended the MLA’s application to a wide range of closed-end and open-end credit products and to broad classes of creditors as originally proposed.… Continue Reading
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Citing Operational Challenges, CFPB May Rewrite TRID
Posted in CFPB, Compliance Resources, Mortgage Servicing, Regulatory Developments, TILA/RESPA, Trending NewsToday, the CFPB issued a letter to various industry trade groups, including the Mortgage Bankers Association, the American Bankers Association, and the Independent Community Bankers of America, acknowledging that the implementation of the “Know Before You Owe” rule (otherwise known as “TRID”) poses many “operational challenges.” Many financial institutions and industry participants do not have… Continue Reading
Regulators Refocus on Commercial Real Estate Lending
Posted in Commercial Real Estate, Compliance Resources, Regulatory DevelopmentsOn December 18, 2015, the Office of the Comptroller of the Currency (OCC), along with the Board of Governors of the Federal Reserve System (FRB) and the Federal Deposit Insurance Corporation (FDIC, together with the FRB and the OCC, the “Banking Agencies”) issued the Interagency Statement on Prudent Risk Management for Commercial Real Estate Lending… Continue Reading
Coping with the CAMELS
Posted in Compliance Resources, CybersecurityIntroduction In connection with a presentation I was asked to make by the Federal Home Loan Bank to some of its member banks, I crafted this article on “Coping with the CAMELS.” As you know, this is an acronym for the six ratings in commercial bank exams – Capital, Asset Quality, Management, Earnings, Liquidity and… Continue Reading
Updated Compliance Resources for the TILA-RESPA Integrated Disclosure Rule
Posted in CFPB, Compliance Resources, Mortgage Servicing, Regulatory Developments, TILA/RESPA, Trending NewsAs many of you know, the effective date of the TILA-RESPA Final Rule and the related TILA-RESPA Amendments has been delayed to October 3, 2015. Please take note of the following updates from the CFPB: Freddie Mac and Fannie Mae Data Standards Freddie Mac and Fannie Mae have released a common industry dataset, called the… Continue Reading
CFPB Allows Consumers to Publish Complaint Narratives in CFPB’s Public Database
Posted in CFPB, Compliance Resources, Regulatory Developments
Dodd-Frank empowered CFPB to treat consumer complaints as an integral part of CFPB’s mission. As of March 1, 2015, CFPB has handled 558,800 complaints on many consumer financial products, including credit cards, mortgages, bank accounts, private student loans, vehicle and other consumer loans, credit reporting, money transfers, debt collection and payday loans. Despite objections from… Continue Reading
Bank Regulatory Agencies Develop Automated Tool to Calculate Risk-Based Capital Requirements for Securitizations
Posted in Basel III, Compliance Resources, Regulatory DevelopmentsToday, the Office of the Comptroller of the Currency (“OCC”) issued a regulatory capital bulletin (“Bulletin”) stating that the OCC, the Federal Reserve Board, and the Federal Deposit Insurance Corporation have developed an automated tool to help national banks and federal savings associations calculate risk-based capital requirements for securitization exposures. This automated tool is not… Continue Reading
Welcome to Bank Law Monitor: A Legal Blog for the Financial Services Industry
Posted in Auto Finance, CFPB, Compliance Resources, Credit Cards, Debt Collection, Marijuana, Mortgage Servicing, Overdrafts, Regulation AB, Regulatory Developments, TILA/RESPA, Trending News, UDAAPWelcome! Graham & Dunn’s Financial Services team is pleased to announce the launch of Bank Law Monitor, a legal blog for the financial services industry. Bank Law Monitor will analyze regulatory developments, report on significant news and market trends, and monitor upcoming regulatory changes that impact the financial services industry. Our goal is to help… Continue Reading