All in Regulatory Update

NCUA Issues Letter Regarding Changes to HMDA’s Loan Origination Threshold

Adam Witmer
HMDA, Regulatory Update

On February 2, 2023, the NCUA issued a letter addressed to federally insured credit unions regarding the change to HMDA’s closed-end loan reporting threshold. According to the NCUA, the agency recognizes that credit unions affected by this change may need time to implement or adjust policies, procedures, systems, and operations to achieve compliance with these reporting requirements. Thus, the NCUA intends to take a flexible supervisory and enforcement approach similar to the approach being taken by the CFPB.

OCC Issues Bulletin Regarding Changes in HMDA Loan Origination Threshold

Adam Witmer
HMDA, Regulatory Update

On February 1, 2023, the OCC issued a bulletin to inform banks and OCC examining personnel that the loan origination threshold for reporting Home Mortgage Disclosure Act (HMDA) data on closed-end mortgage loans has changed. This is after a court decision was issued that the threshold for reporting is now 25 closed-end mortgage loans originated in each of the two preceding calendar years.

CFPB Proposes Rule to Control Credit Card Late Fees

Adam Witmer
Regulatory Update

On February 1, 2023, the CFPB issued a proposed rule to curb excessive credit card late fees that cost American families about $12 billion each year. According to the CFPB, major credit card issuers continue to profit off late fees that are protected by an expansive immunity provision. The Bureau believes that the proposed rule would help ensure that over the top late fee amounts are illegal. 

FRB Issues Policy to Level Bank Limitations

Adam Witmer
Regulatory Update

On January 27, 2023, the Federal Reserve Board issued a policy statement to promote a level playing field for all banks with a federal supervisor, regardless of deposit insurance status. The statement makes clear that uninsured and insured banks supervised by the Board will be subject to the same limitations on activities, including novel banking activities, such as crypto-asset-related activities.

CFPB Study Finds Credit Scores Increased During the Pandemic

Adam Witmer
Regulatory Update

On January 25, 2023, the CFPB published a blog post analyzing the results of an analysis issued by the CFPB’s Office of Research in April of 2021 indicating that the distribution of credit scores shifted upward during the pandemic. The report shows that fewer consumers had difficulty paying a bill in the initial months of the COVID-19 pandemic than one year earlier and that both credit scores and CFPB financial well-being scores increased.

FinCEN Issues Alert on Potential Real Estate Investments by Sanctioned Russian Entities

Adam Witmer
BSA, Regulatory Update

On January 25, 2023, FinCEN issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their family members, and the entities through which they act. The alert lists potential red flags and typologies involving attempted sanctions evasion in the commercial real estate sector, and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations. 

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