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#1639968 - 12/16/11 02:25 PM CFPB's new Regs O and N
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
So, they just started and I'm already confused. Reading the Fed Registers from your Top Stories. For Reg O it states, "The interim final rule will have no unique impact on depository institutions or credit unions with $10 billion or less in assets".

So is a national bank with less than $10 billion assets not subject to new Reg O?

Reg N applies to person over which the Federal Trade Commission has jurisdiction under the FTCA. Again, same question. Does this impact us?
Upon further reading of Reg N, it appears to apply, not to the bank, but rather to the Mortgage Assistance Relief Service Provider, which does not include the "dwelling loan holder".
Last edited by upstateNY; 12/16/11 03:05 PM.
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#1640039 - 12/16/11 03:57 PM Re: CFPB's new Regs O and N upstateNY
JobSecurity Offline
Platinum Poster
Joined: Oct 2009
Posts: 604
I am not clear on this either, found the following out on the web, but if that is true why does the FR say specifically say it will have not unique impact on $10 billion or less??? Would someone who is smarter please set us straight?

Several federal agencies have authority over entities in the financial services marketplace. The FTC has broad jurisdiction over nonbank financial companies, including nonbank mortgage companies, mortgage brokers, finance companies, and units of bank holding companies. The FTC Act and the other statutes that the FTC enforces specifically exempt banks, savings and loan institutions, and federal credit unions from the agency’s jurisdiction.

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#1640497 - 12/19/11 04:03 PM Re: CFPB's new Regs O and N JobSecurity
Sinatra Fan Offline
Power Poster
Sinatra Fan
Joined: Jul 2002
Posts: 5,568
New Jersey
Based upon our recent OCC examination experience, the $10 billion threshold will become operationally insignificant. The OCC directed us to do certain things that are required for banks over $10 billion, but not for banks under that amount (we are just over $1 billion).

If you are over $10 billion, they will say it's required by regulation. If you are under $10 billion, they will say it's "best practice" and still require it. That at least is the general sense I'm getting from the OCC. I can't speak to the other regulatory bodies.
Last edited by Sinatra Fan; 12/19/11 04:04 PM.
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