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#2232538 - 03/06/20 04:10 PM Fed vs. FDIC Regulations
NoJustNo Offline
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Joined: Oct 2013
Posts: 221
Midwest
Can anyone give me a good example of situations where the Fed and FDIC's regulations differ. Some bankers seem to have trouble grasping that it *is* important to get your citation based on your regulator!

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#2232543 - 03/06/20 04:21 PM Re: Fed vs. FDIC Regulations NoJustNo
raitchjay Online
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Joined: Oct 2009
Posts: 9,105
OK
Not currently a thing, but i remember the Fed being the only prudential body to be ok with balloon loans in regards to HPMLs for awhile.
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#2232547 - 03/06/20 04:27 PM Re: Fed vs. FDIC Regulations NoJustNo
raitchjay Online
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Joined: Oct 2009
Posts: 9,105
OK
It's been a few years and i forget all the details (since ATR and QM rules, and CPFB ownership sort of makes it all obsolete), but there was a FRB letter on the issue that Fed banks relied on and everyone else couldn't.
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#2232554 - 03/06/20 05:19 PM Re: Fed vs. FDIC Regulations NoJustNo
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Off of the top of my head:
The Fair Housing Act (Equal Housing Lender vs. Equal Opportunity)
Some interpretations in Flood - especially the timing of the notice.
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#2232606 - 03/06/20 10:59 PM Re: Fed vs. FDIC Regulations NoJustNo
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,750
On the Net
I think there is the occasional issue that applies to one without a corresponding requirement applicable to another, like this:

12 U.S.C. Sec. 376 says, Rate of interest paid to directors, etc.
Sec. 376 [Federal Reserve Act, Sec. 22] No member bank shall pay to any director, officer, attorney, or employee a greater rate of interest on the deposits of such director, officer, attorney, or employee than that paid to other depositors on similar deposits with such member bank.

If its a nonmember bank, is there any corresponding requirement?
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#2232775 - 03/11/20 04:08 PM Re: Fed vs. FDIC Regulations NoJustNo
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Nonmember banks could be subject to a similar state law or regulation, but I am not aware of a corresponding federal rule for nonmember banks.
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