Compliance Action, Volume 23, Number 3
*** From the Editor: Articles uploaded ***
Check back frequently and catch the new content as it is published! Once the issue is complete, the .pdf version will be available (and you will receive an email alert).
- Patti Joyner Blenden, Editor
The Community Reinvestment Act, known as CRA, has come a long way since its inception.
We are delighted to welcome Susan to our Advisory Board.
Regulation Z Ability to Repay (ATR) Monthly Payment Underwriting Calculation Quick Reference Guide
The Standard Ability-to-Repay (ATR) and Qualified Mortgage (QM) regulations require Creditors to determine a consumer’s ability-to-repay the covered transaction using the payment calculation methods mandated in Regulation Z Section 43.
Collectively, the FRB, FDIC and the OCC adopted a final rule effective April 9, 2018, (83 FR 15019 - 15036) creating a new definition of, and a separate category for, commercial real estate (CRE) transactions. As a result, banks must now consider three general real estate transaction value (loan amount) thresholds ($250,000, $500,000 and $1 million) when deciding if a real estate appraisal or an evaluation is required. We have also included a chart to assist you in understanding the general valuation requirements.
In the Editor's Opinion
Frivolous and Irrelevant - Ouch!
I think we would all agree that new regulations, guidance, and even sometimes unpredictable recent interpretations set incredibly high standards for ensuring customers are protected and respectfully treated fairly. Yet sometimes, you run across provisions that seem as out of place as a bull in a china shop.
Compliance Q & A
- HMDA Reporting: What to do when commercial lending involves a residential lien
- Reg B (ECOA) audit question
- GDPR and US institutions
The Consumer Financial Protection Bureau (CFPB) issued a final rule on April 26, 2018 (2018 TILA-RESPA rule) settling a long-debated TILA-RESPA Integrated Disclosure (TRID) rule question
FFIEC CDD Exam Procedures
- Patti Joyner Blenden
- Board of Advisors:
- John S. Byrne, Esq.
Cliff E. Cook
Julia A. Gliha, MBA
Michael D. Maher
Carl G. Pry
Susan A. Rich
Robert G. Rowe, III, Esq.