2024 HMDA Exemption Threshold

Adam Witmer
HMDA, Regulatory Update

On December 18, 2023, the CFPB adjusted the HMDA exemption threshold from $54 million to $56 million. The adjustment is based on the 4.1 percent increase in the average of the CPI-W for the 12-month period ending in November 2023 (up from 4.7 in 2021 and 8.6 in 2022). Therefore, banks, savings associations, and credit unions with assets of $56 million or less as of Dec. 31, 2023, are exempt from collecting data in 2024.

CFPB Shuts Down Commonwealth Financial Systems for Illegal Debt Collection

Adam Witmer
Regulatory Update, FCRA

On December 15, 2023, the CFPB took action against a medical debt collector, Commonwealth Financial Systems, for illegally trying to collect unverified medical debts after consumers disputed the validity of the debts. With its headquarter in Dickson City, Commonwealth Financial Systems is a nonbank corporation engaged in  third-party debt collection where it specializes in the collection of past-due medical debts and furnishes information about consumer collection accounts to consumer reporting companies. 

OCC’s 2023 Annual Report

Paula Parras
Regulatory Update

On December 11, 2023, the OCC issued its annual report to Congress which provides an overview of the condition of the federal banking system. The annual report can be beneficial to compliance professionals as it discusses the OCC's strategic priorities and details agency regulatory and policy initiatives.

OCC’s Fall 2023 Semiannual Risk Perspective

Adam Witmer
Regulatory Update

On December 7, 2023, the OCC released the Fall 2023 edition of its publication Semiannual Risk Perspective. According to the report, economic growth remained solid in the first half of 2023 despite higher interest rates and profitability for the federal banking system also improved even as banks continued to navigate a higher interest rate environment, uncertain economic climate, and fallout from the failure of three regional banks in the spring.

OCC’s Guidance on ‘Buy Now, Pay Later’ Lending

Adam Witmer
Regulatory Update

On December 6, 2023, the OCC issued guidance to national banks and federal savings associations to address the risks associated with “buy now, pay later” lending. The guidance focuses on the risk management of buy now, pay later (BNPL) loans and  notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes. Banks also should ensure that marketing materials and disclosures are clear and conspicuous.

OCC’s Acting Deputy Comptroller Testifies on Financial Technology

Adam Witmer
Regulatory Update

On December 5, 2023, OCC’s Deputy Comptroller for Compliance Policy and Acting Deputy Comptroller for the Office of Financial Technology Donna Murphy today testified on the activities and initiatives of the OCC Office of Financial Technology before the Subcommittee on Digital Assets, Financial Technology and Inclusion, Committee on Financial Services of the U.S. House of Representatives. Ms. Murphy spoke about the OCC's role in monitoring and regulating banks' use of new and emerging technologies.

FDIC Updates Consumer Compliance Exam Manual

Adam Witmer
Regulatory Update

On November 30, 2023, the FDIC updated sections of the Consumer Compliance Examination Manual. The Consumer Compliance Examination Manual is a primary resource and reference tool for FDIC compliance examination staff when conducting Consumer Compliance and CRA examinations. It incorporates examination policies, procedures, and guidance and is available on the FDIC website as a resource for FDIC staff, bankers, and other members of the public.

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