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#2257769 - 08/05/21 10:04 PM
OCC Contact Information Change
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Power Poster
Joined: Nov 2003
Posts: 3,738
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I am having brain fog or failure -I'm not sure which. The OCC sent out Bulletin 2021-35 and changed their contact information. They included the Fair Housing Act. We have Equal Housing Lender sign and for the life of me I can't remember if that is the same thing as the Fair Housing Act poster they are referring to. I even looked up the citation and I am still not making the mental connection. Someone help!
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#2257792 - 08/06/21 04:59 PM
Re: OCC Contact Information Change
Tesla
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Joined: Jul 2001
Posts: 84,326
Galveston, TX
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#2257793 - 08/06/21 05:04 PM
Re: OCC Contact Information Change
Tesla
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Power Poster
Joined: Nov 2003
Posts: 3,738
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Thank you. I kept thinking it was that poster but then I kept getting hung up on the Fair Housing Act thing. Sometimes I think I need to retire.
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#2257835 - 08/06/21 09:30 PM
Re: OCC Contact Information Change
Tesla
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Power Poster
Joined: Nov 2003
Posts: 3,738
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This changes the address on Adverse Action Notices too, right?
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#2257836 - 08/06/21 09:54 PM
Re: OCC Contact Information Change
Tesla
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Joined: Oct 2000
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On the Net
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Appendix A to Reg B had this for the OCC: Office of the Comptroller of the Currency, Customer Assistance Group, 1301 McKinney Street, Suite 3450, Houston, TX 77010–9050
Per 2021-35 Reg B adverse actions will now be addressed to: Office of the Comptroller of the Currency Customer Assistance Group P. O. Box 53570 Houston, TX 77052
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#2257837 - 08/06/21 09:58 PM
Re: OCC Contact Information Change
Tesla
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Power Poster
Joined: Nov 2003
Posts: 3,738
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Thank you! I checked BOL and it wasn't updated and you guys are ALWAYS on top of things and I thought Oh No! I told the line to order new signs and update systems and they didn't need to. LOL! Thank you for all you do!
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#2257840 - 08/06/21 10:05 PM
Re: OCC Contact Information Change
Tesla
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The OCC has said it's so, but the CFPB "owns" Reg B so I'm sure we'll get the change denoted ASAP.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#2257841 - 08/06/21 10:06 PM
Re: OCC Contact Information Change
Tesla
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Power Poster
Joined: Nov 2003
Posts: 3,738
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Totally get it! Thanks again and have a great weekend!
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
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#2257855 - 08/09/21 02:33 PM
Re: OCC Contact Information Change
Tesla
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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FYI -- The BOL page for Appendix A to Regulation B has been updated to add a notice that the OCC has updated the OCC address to appear on adverse action notices, along with the 11/3/2021 deadline for getting forms updated. That notice will remain until the CFPB issues an update of the regulation to make the change.
Last edited by John Burnett; 08/09/21 02:52 PM.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2257924 - 08/09/21 09:09 PM
Re: OCC Contact Information Change
John Burnett
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Platinum Poster
Joined: Aug 2016
Posts: 556
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So we if are an OCC-regulated bank we are good to go ahead and update our posters and notices with this new address (even though CFPB hasn't updated the regulation to make this change)?
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#2257927 - 08/09/21 09:44 PM
Re: OCC Contact Information Change
Tesla
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10K Club
Joined: Jul 2001
Posts: 84,326
Galveston, TX
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Unless you are over $10 Billion, the CFPB is not your primary regulator. The Appendix in Regulation B is just for informational purposes only.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2257986 - 08/10/21 06:43 PM
Re: OCC Contact Information Change
TeamComply
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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So we if are an OCC-regulated bank we are good to go ahead and update our posters and notices with this new address (even though CFPB hasn't updated the regulation to make this change)? Yes. Get it done by November 3.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2259464 - 09/09/21 04:53 PM
Re: OCC Contact Information Change
Tesla
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Platinum Poster
Joined: Aug 2016
Posts: 556
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Can someone confirm the size requirement of the EHL poster (that will include this revised address)?
Isn't it larger... like 11 x 14? Or does it matter???
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#2259472 - 09/09/21 05:29 PM
Re: OCC Contact Information Change
Tesla
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10K Club
Joined: Jul 2001
Posts: 84,326
Galveston, TX
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11 x 14 - although there is no OCC specific regulation. But all other regulators and DUD requires that size.
I was going to edit DUD as that was suppose to be HUD - but then thought about and decided they are about the same
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2259474 - 09/09/21 05:41 PM
Re: OCC Contact Information Change
rlcarey
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Platinum Poster
Joined: Aug 2016
Posts: 556
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rlcarey - thanks for this info!
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#2259688 - 09/14/21 05:21 PM
Re: OCC Contact Information Change
Tesla
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Member
Joined: Feb 2016
Posts: 91
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If you're an OCC Bank over $10 billion should your Equal Housing Lender poster list HUD and the new address for the OCC in the upper portion for the Fair Housing Act, then list the CFPB at the bottom for the ECOA?
Or is the CFPB only supposed to be used for the ECOA notice on adverse action notices?
Thanks,
Larry
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#2259694 - 09/14/21 06:07 PM
Re: OCC Contact Information Change
Tesla
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10K Club
Joined: Jul 2001
Posts: 84,326
Galveston, TX
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_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2259701 - 09/14/21 08:05 PM
Re: OCC Contact Information Change
Tesla
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Member
Joined: Feb 2016
Posts: 91
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Unfortunately, I had already read the OCC bulletin but still need a little help understanding it. It says to list the OCC on the Fair Housing Act poster and to list the CFPB on the ECOA statement (with a footnote referencing 1002.9(b) for adverse action notices).
However, the bottom portion of the poster also includes an ECOA statement, so I'm assuming we should list the CFPB on that part of the poster. Am I reading that correctly?
Thanks,
Larry
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#2259709 - 09/14/21 09:44 PM
Re: OCC Contact Information Change
Tesla
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10K Club
Joined: Jul 2001
Posts: 84,326
Galveston, TX
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Banks should use the following address in their Fair Housing Act posters:
Office of the Comptroller of the Currency Customer Assistance Group P. O. Box 53570 Houston, TX 77052
The end.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2260279 - 09/27/21 02:38 PM
Re: OCC Contact Information Change
rlcarey
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Platinum Poster
Joined: Aug 2016
Posts: 556
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Last edited by TeamComply; 09/27/21 02:41 PM.
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#2260280 - 09/27/21 03:08 PM
Re: OCC Contact Information Change
Tesla
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Gold Star
Joined: Jul 2007
Posts: 305
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The OCC changed the wording in the CRA public notice when they issued the "new" CRA rules. Since they are in the process of rescinding those changes, which wording should the public notice have?
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"Life begins at the end of your comfort zone."
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#2260283 - 09/27/21 03:25 PM
Re: OCC Contact Information Change
dottiec
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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The OCC changed the wording in the CRA public notice when they issued the "new" CRA rules. Since they are in the process of rescinding those changes, which wording should the public notice have? I recommend waiting until we see the OCC's rescinding rules to determine what's being rescinded and what isn't.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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