On October 20, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau (CFPB), and the National Credit Union Administration (each, a Banking Agency, and collectively, the Banking Agencies) published a proposed rule (the Proposed Rule) that would codify the Interagency Statement Clarifying the Role of Supervisory Guidance issued by the Banking Agencies on September 11, 2018 (the 2018 Statement). The 2018 Statement provided that regulatory guidance did not have the force and effect of law and did not create binding obligations on the public.
Continue Reading Banking Agencies Issue Proposed Rule Addressing Role of Supervisory Guidance
Consumer Financial Protection Bureau
US Banking Agencies Issue Statement on Alternative Date in Credit Underwriting
By Christina Grigorian on
Posted in Banking
On December 3, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Consumer Financial Protection Bureau (CFPB) and the National Credit Union Administration (the Banking Agencies) released interagency guidance related to the use of alternative data for purposes of underwriting credit (the Guidance).
Continue Reading US Banking Agencies Issue Statement on Alternative Date in Credit Underwriting
Revised Interagency Examination Procedures for Consumer Compliance
By Jeffrey M. Werthan on
Posted in Banking
As of May 1, the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council developed interagency examination procedures for:
- Truth in Lending Act (TILA), implemented by Regulation Z; and
- Real Estate Settlement Procedures Act (RESPA), implemented by Regulation X.
These procedures reflect Consumer Financial Protection Bureau amendments to Regulations Z and X published in the Federal Register in December 2013 and February 2015. Most of the changes to the procedures relate to the integrated mortgage disclosure requirements under TILA and RESPA, commonly referred to as the TRID requirements, which go into effect August 1 for all national banks and federal savings associations that offer consumer credit products covered by TILA and RESPA.
Continue Reading Revised Interagency Examination Procedures for Consumer Compliance