Bank Notes

  • May 29, 2018
    On Tuesday, May 29, 2018, CBA submitted comments on the Bureau of Consumer Financial Protection’s external engagements. The comments are part of the Bureau’s ongoing requests for information. “CBA and its member institutions believe that informed, transparent governing is the best way to produce informed policy that is good for both banks and consumers. A well-functioning Bureau is critical to...
  • May 9, 2018
    On Wednesday, May 9, 2018, CBA sent a letter to the Financial Crimes Enforcement Network (FinCEN) expressing full support of its efforts to crack down on illegal activities through its final Customer Due Diligence Rule (CDD rule). CBA expressed appreciation for the implementation time banks were given to comply with the complex data collection rule, particularly following unexpected developments...
  • May 7, 2018
    On Monday, May 7, 2018, CBA and the Financial Services Roundtable (FSR) filed comments on the RFI regarding the Bureau Rules of Practice for Adjudication Proceedings. The associations stressed the importance of expeditious resolution and urged the Bureau to look to the Federal Rules of Civil Procedure (FRCP) and the Federal Rules of Evidence (FRE) as benchmarks for specific timelines, breadth of...
  • May 7, 2018
    On Monday, May 7, 2018, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 5,852 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, and mortgage companies. Released today are loan-level HMDA data that cover 2017...
  • May 2, 2018
    On Wednesday, May 2, 2018, the OCC issued a bulletin on adopting a final rule to increase the appraisal threshold for commercial real estate (CRE) transactions from $250,000 to $500,000. This threshold increase means that transactions at or below this level do not require appraisals that conform to Title XI of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 and the...
  • April 26, 2018
    On Thursday, April 26, 2018, the CFPB finalized its amendment to its “Know Before You Owe” mortgage disclosure rule. The amendment aims to address when mortgage lenders with a valid justification may pass on increased closing costs to consumers and disclose them on a Closing Disclosure. The Know Before You Owe mortgage disclosure rule took effect Oct. 3, 2015. The Bureau’s rule created new Loan...
  • April 20, 2018
    On Friday, April 20, 2018, the CFPB, in a coordinated action with the OCC, announced a settlement with Wells Fargo Bank , after the agencies found Wells Fargo violated the Consumer Financial Protection Act through the way the bank administered its insurance program related to auto loans. Under the terms of the consent orders, Wells Fargo must pay a $1 billion penalty, with $500 million going to...
  • April 18, 2018
    On Wednesday, April 18, 2018, the CFPB released their independent audit, facilitated by KPMG LLP, which covers the period from July 18, 2017 to February 28, 2018. KPMG evaluated the CFPB’s budget process relative to its priorities and procedures established over budget formulation, execution, and monitoring; monitoring and oversight of the interagency agreement with the Bureau of Fiscal Service;...
  • April 18, 2018
    On Wednesday, April 18, 2018, the U.S. Senate passed a Congressional Review Act (CRA) Resolution, which was introduced by Jerry Moran (R-Kan.), to overturn the CFPB's 2013 Auto Bulletin. A companion bill has been introduced in the House of Representatives by Congressman Lee Zeldin (R-N.Y.) and CBA expects this resolution to pass too, thereby sending the CRA to President Donald Trump's desk for...
  • April 18, 2018
    On Wednesday, April 18, 2018, the Senate Commerce Committee held a hearing entitled "Abusive Robocalls and How We Can Stop Them." While the hearing focused on illegal robocalls, and particularly enforcement against such calls and available technology tools, CBA used the hearing as an opportunity to distinguish between robocalls and calls from legitimate businesses to their customers. CBA sent a...

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