Search Results

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

Revised Texas Mortgage Company Disclosure

by | Dec 29, 2017 | ,

Effective January 7, 2018, the Finance Commission of Texas on behalf of the Department of Savings and Mortgage Lending revised the Texas Mortgage Company Disclosure (the “Disclosure”) that a residential mortgage loan originator sponsored by a Texas licensed residential mortgage loan company must give to a residential mortgage loan applicant with the initial application for a residential mortgage loan. The revised disclosure is hyperlinked to this memorandum: click here. A facsimile of the revised Disclosure is also attached to this memorandum on page 2.

CRA Asset-size Thresholds Revised for 2018

by | Dec 28, 2017 |

In the December 27, 2017 issue of the Federal Register (82 FR 61143, click here), the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) published a joint final rule amending their respective Community Reinvestment Act (CRA) regulations to adjust the asset-size thresholds used to define “small bank,” “small savings association,” “intermediate small bank,” and “intermediate small savings association,” as set out below:

Asset-size Thresholds Revised for HMDA and TILA in 2018

by | Dec 28, 2017 | , ,

In the December 27, 2017 issue of the Federal Register, the following annually revised asset-size thresholds were published to be effective January 1, 2018: Home Mortgage Disclosure Act/Regulation C (82 FR 61145) The CFPB has added comment -2 under the definition “Financial institution” in §1003.2(g) of the Staff Commentary to Regulation C (12 CFR part 1003) to increase the asset-size exemption threshold for banks, savings associations, and credit unions for HMDA data collected in 2018 to $45 million. Therefore, effective January 1, 2018, banks, savings associations, and credit unions with assets at or below $45 million as of December 31, 2017, are exempt from collecting HMDA data for 2018. (Note: An institution’s exemption from collecting HMDA data in 2018 does not affect its responsibility to report data it was required to collect in 2017.)

CFPB Issues Public Statement Regarding 2018 HMDA Data

by | Dec 27, 2017 | ,

On December 21, 2017, the CFPB issued a Public Statement for HMDA data collected in 2018 and reported in 2019. In the Public Statement, the CFPB states that it does not intend to require data resubmission unless data errors are material or assess penalties with respect to errors in data collected in 2018 and reported in 2019, and that any examinations of 2018 HMDA data will be diagnostic to help institutions identify compliance weaknesses and will credit good-faith compliance efforts.

Updated Exemption Thresholds for Consumer Credit Transactions and Higher-

by | Nov 30, 2017 | ,

In the November 9, 2017 issue of the Federal Register (82 FR 51977) (click here), the Board of Governors of the Federal Reserve System (“Board”) and the Bureau of Consumer Financial Protection (“CFPB”) published a final rule increasing the threshold for consumer credit transactions exempt from the Truth In Lending Act. Also in the November 9, 2017 issue of the Federal Register (82 FR 51973) (click here), the Board, CFPB and the Office of the Comptroller of the Treasury (“OCC”) published a final rule increasing the threshold exemption from required appraisals for higher-priced mortgage loans. In both instances, the final rules will take effect on January 1, 2018.

Article Categories

Join Our Mailing List