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#1884255 - 01/08/14 05:42 PM CFPB and Banks over 10 Billion
JUST CALL ME CRA Offline
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I understand that CRA was not included in the laws that CFPB regulates. So if a bank goes over $10 Billion and CFPB becomes their primary compliance regulator, who does the bank's CRA exam. Also, is there a piece of regulation that tells when the CFPB's compliance supervision begins after the bank exceeds the $10 billion threshold? Is it immediate?
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#1884267 - 01/08/14 06:06 PM Re: CFPB and Banks over 10 Billion JUST CALL ME CRA
Tennismom Offline
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http://www.buckleysandler.com/uploads/36...resentation.pdf

This material was presented to their clients in 2011 - I don't believe it has changed.

Generally, the CFPB is tasked with regulating and
enforcing the “enumerated” consumer protection laws:
– Title XIV of Dodd-Frank - Mortgage Reforms
– Title X of Dodd-Frank - Consumer Financial Protection Act
– Fair Credit Reporting Act, FDCPA
– RESPA, TILA, HOEPA, SAFE Act, HMDA
– Gramm-Leach-Bliley Act (with exceptions)
– Truth in Savings Act
– Electronic Funds Transfer Act, Fair Credit Billing Act
- Durbin Amendment remains under FRB

*Does not include Fair Housing Act and Community Reinvestment Act

Calculation of $10B threshold is based on total assets
Starting point for determination is June 30, 2011 Call Report Change in status will result after four consecutive quarters
above/below threshold


Last edited by tennismom; 01/08/14 06:07 PM.
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#1884274 - 01/08/14 06:17 PM Re: CFPB and Banks over 10 Billion JUST CALL ME CRA
JUST CALL ME CRA Offline
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Posts: 133
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So is it reasonable to assume that when a bank goes over $10 Billion, the entity that was there primary regulator before will do their CRA exams?
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#1884312 - 01/08/14 07:38 PM Re: CFPB and Banks over 10 Billion JUST CALL ME CRA
Pale Rider Offline
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under the Lone Star
That is the way it is for us....good old OCC
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#1884358 - 01/08/14 08:51 PM Re: CFPB and Banks over 10 Billion JUST CALL ME CRA
Tennismom Offline
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Tennismom
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Same here....FDIC

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#1884372 - 01/08/14 09:03 PM Re: CFPB and Banks over 10 Billion JUST CALL ME CRA
Kathleen O. Blanchard Offline

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Yes, as stated above, if a regulation was not transferred to the CFPB, for the banks above $10 billion their primary regulator continues to examine on those regulations, such as CRA.
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