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Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.

Proposed Rule on Minimum Requirements for Appraisal Management Companies

In the April 9, 2014 issue of the Federal Register (79 FR 19521) six federal regulatory agencies, CFPB, FDIC, FHFA, FRB, NCUA and OCC, published a proposed rule (click here) to implement minimum requirements to be applied by States in the registration and supervision of appraisal management companies (AMCs). In a memorandum dated March 24, 2014, we advised our clients of the of the proposed rule before its publication in the Federal Register and provided a redacted summary of the proposed rule taken from the press release issued by the above agencies (memo).

Federal Agencies Issue Proposed Rule on Minimum Requirements for Appraisal Management Companies

Today six federal regulatory agencies, CFPB, FDIC, FHFA, FRB, NCUA and OCC, issued a proposed rule (click here) to implement minimum requirements to be applied by States in the registration and supervision of appraisal management companies (AMCs). Publication of the proposed rule in the Federal Register is expected shortly. In the meantime, a summary of the proposed rule is contained in the press release also released today by the above agencies. The text of the press release, redacted for brevity, is reprinted below:

CFPB Proposed Amendments to the 2013 Mortgage Rules Under Regulation B, Regulation X, and Regulation Z

In the July 2, 2013 issue of the Federal Register (78 FR 39902) the Consumer Financial Protection Bureau (CFPB) published a proposed rule, click here, to clarify or revise regulatory provisions and official interpretations primarily relating to the 2013 Mortgage Servicing Final Rules (see, 78 FR 10695 (Reg. X) and 78 FR 10901 (Reg. Z), Feb. 14, 2013) and the 2013 Loan Originator Compensation Final Rule (see, 78 FR 11279, Feb. 15, 2013). The proposed rule also proposes modifications to the effective dates for provisions adopted by the 2013 Loan Originator Compensation Final Rule, and certain technical corrections and minor refinements to Regulations B, X, and Z. In the July 2, 2013 issue of the Federal Register (78 FR 39902) the Consumer Financial Protection Bureau (CFPB) published a proposed rule, click here, to clarify or revise regulatory provisions and official interpretations primarily relating to the 2013 Mortgage Servicing Final Rules (see, 78 FR 10695 (Reg. X) and 78 FR 10901 (Reg. Z), Feb. 14, 2013) and the 2013 Loan Originator Compensation Final Rule (see, 78 FR 11279, Feb. 15, 2013). The proposed rule also proposes modifications to the effective dates for provisions adopted by the 2013 Loan Originator Compensation Final Rule, and certain technical corrections and minor refinements to Regulations B, X, and Z.

CFPB Amends Regulation B to Require Providing Copies of Appraisals to Loan Applicants

In the January 31, 2013 Federal Register (78 FR 7248), the Bureau of Consumer Financial Protection (CFPB) issued a final rule (the Appraisal Rule) that amends §1002.14 of Regulation B, the Form C-9 Notice, and the Official Interpretations to §1002.14 to require creditors to provide free copies of all written appraisals and other written valuations developed in connection with an application for a loan that is to be secured by a first lien on a dwelling. The Appraisal Rule also requires creditors to notify applicants in writing of the right to receive a copy of each written appraisal at no additional cost. The Appraisal Rule is effective January 18, 2014, and applies to loans to be secured by first liens on dwellings for which the creditor receives an application on or after January 18, 2014.

Proposed Rule on Property Appraisals for Higher-Risk Mortgage Loans

In today’s Federal Register (77 FR 54722), the six federal financial regulatory agencies – Board of Governors of the Federal Reserve System (FRB), Bureau of Consumer Financial Protection (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), National Credit Union Administration (NCUA), and Office of the Comptroller of the Currency (OCC) – published a proposed rule amending Regulation Z to establish appraisal requirements for higher-risk mortgage loans.

CFPB Issues Proposed Rule in Federal Register to Amend Regulation B Rules on Providing Appraisals to Loan Applicants

In the August 21, 2012 Federal Register (77 FR 50390), the Bureau of Consumer Financial Protection (CFPB) issued a proposed rule that would amend §1002.14 of Regulation B, the Form C-9 Notice, and the Official Interpretations to §1002.14 to require creditors to provide free copies of all written appraisals and valuations developed in connection with an application for a loan to be secured by a first lien on a dwelling. The proposed rule also would require creditors to notify applicants in writing of the right to receive a copy of each written appraisal or valuation at no additional cost. This proposed rule has a comment period that ends on October 15, 2012, and was the subject of our August 17, 2012 memorandum prior to the issuance of the proposed rule in the Federal Register.

Proposed Rule on Property Appraisals for Higher-Risk Mortgage Loans

In an August 15, 2012 press release, the six federal financial regulatory agencies – Board of Governors of the Federal Reserve System (FRB), Bureau of Consumer Financial Protection (CFPB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), National Credit Union Administration (NCUA), and Office of the Comptroller of the Currency (OCC) – issued a proposed rule to establish appraisal requirements for higher-risk mortgage loans.

Bureau of Consumer Financial Protection Issues New Regulations

In our December 16, 2011, memorandum we advised you that the Bureau of Consumer Financial Protection (CFPB) had begun the process of republishing the regulations implementing the consumer financial protection laws for which Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) had transferred rulemaking authority to the CFPB from seven Federal agencies (i.e., FRB, FDIC, FTC, NCUA, OCC, OTS, and HUD) as of July 21, 2011. The CFPB is continuing this process of republishing the regulations implementing those laws by publishing in the Federal Register (Vol. 76, Issues 243, 244, 245, 246, 248 and 250) the following additional interim final regulations, effective December 30, 2011:

Amendments to ECOA and FCRA Adverse Action Notice Model Forms

In the July 15, 2011 Federal Register, the Federal Reserve Board (FRB) published a final rule amending the model notices in the Equal Credit Opportunity Act’s (ECOA) Regulation B (12 CFR Part 202) to implement the new credit score disclosure requirements of section 1100F of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) for adverse action notices under the Fair Credit Reporting Act (FCRA).

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