Beginning October 7, 1996, HUD's new rules restricting compensation to employees take effect.
When the new CRA regulation was published, the term "performance context" sounded like a fact - scientific and solid. In practice, it has not been clear.
HUD's latest rulemaking on RESPA is beginning to send shock waves through the banking industry as they design compliance procedures for the new rules.
It's always a good idea to maintain a regular compliance training schedule. Each regulation should be revisited periodically.
A lot of banks are biding their time and watching FinCEN instead of plunging in and exempting customers using the interim procedures. Banks offer a variety of excuses for their delay.