In the December 21, 2018, issue of the Texas Register (Vol. 51, No. 43) the Texas Department of Housing and Community Affairs published the following Notice regarding its latest Mortgage Credit Certificate Program to assist eligible very low, low, and moderate income first-time homebuyers with the purchase of a residence located within the State of Texas. Notice to Public and …
CRA Asset-size Thresholds Revised for 2019
In the December 27, 2018, issue of the Federal Register (83 FR 66601, click here) the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), and Federal Deposit Insurance Corporation (FDIC) (collectively, the Agencies) published a joint final rule amending their respective Community Reinvestment Act (CRA) regulations to adjust the asset-size thresholds …
VA Revises Cash-out Home Refinance Loan Regulations
On May 24, 2018, the “Protecting Veterans from Predatory Lending Act” (herein “VA Act”) was signed into law, effective as of that date, as section 309 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (Public Law 115-174). The VA Act, codified at 38 U.S.C. 3709, provides new statutory criteria for determining when, in general, the VA may guarantee …
HUD Removes Ten-Year Home Warranty Protection Plan Requirements For High-LTV FHA Single Family Loans
In the December 14, 2018, issue of the Federal Register (83 FR 64269, click here) HUD published a final rule (“Rule”), effective March 14, 2019, that removes the regulations in 24 CFR 203.18 and 203.200–209 that require borrowers to purchase 10-year home warranty protection plans in order to qualify for FHA mortgage insurance for high loan-to-value mortgages where the dwelling …
CFPB Releases Beta Version of 2018 HMDA Data Platform
As a companion to the HMDA Examiner Transaction Testing Guidelines memorandum posted on our website yesterday, www.bmandg.com/resources/, this memorandum advises you that the CFPB has released a beta version of the 2018 HMDA data platform. The beta release provides financial institutions an opportunity to become familiar with the 2018 HMDA Platform and determine whether their sample 2018 data comply …
HMDA Examiner Transaction Testing Guidelines
As the 2018 HMDA data reporting deadline of March 1, 2019, is approaching, this memorandum is to remind our clients who report HMDA date of the Federal Financial Institutions Examination Council’s HMDA Examiner Transaction Testing Guidelines published last year on August 22, 2017, which will apply to the examination of HMDA data collected in 2018. The federal agencies that are …
Federal Regulatory Agencies Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing
On December 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the Agencies) issued a Joint Statement (click here) to encourage banks to consider, evaluate, and, where appropriate, responsibly implement innovative approaches …
Updated Exemption Thresholds for Consumer Credit Transactions and Higher-Priced Mortgage Loan Appraisals
In the November 23, 2018 issue of the Federal Register (83 FR 59276) (click here), the Board of Governors of the Federal Reserve System (“Board”) and the Bureau of Consumer Financial Protection (“CFPB”) published final rules increasing the threshold for consumer credit transactions exempt from the Truth In Lending Act. Also in the November 23, 2018 issue of the Federal …
FDIC Request for Comments and Information on Small-dollar Credit Products by FDIC-supervised Financial Institutions
This memorandum does not address residential mortgage lending topics; however, it will be of interest to our FDIC-supervised financial institution clients. In the November 20, 2018, issue of the Federal Register (83 FR 58566, click here), the FDIC published a request for information (RFI) seeking comments and information from interested parties on small-dollar lending, including steps that can be taken …
VA Changes to Qualified Mortgage Loans
On May 24, 2018, the “Protecting Veterans from Predatory Lending Act” (“VA Act”) was signed into law, effective as of that date, as section 309 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (Public Law 115-174). The VA Act, attached to this memorandum as Exhibit A, supersedes certain elements of the Interim Final Rule (“IFR”) published by VA …