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#2257769 - 08/05/21 10:04 PM OCC Contact Information Change
Tesla Offline
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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
rlcarey Online
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#2257793 - 08/06/21 05:04 PM Re: OCC Contact Information Change Tesla
Tesla Offline
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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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#2257835 - 08/06/21 09:30 PM Re: OCC Contact Information Change Tesla
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This changes the address on Adverse Action Notices too, right?
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#2257836 - 08/06/21 09:54 PM Re: OCC Contact Information Change Tesla
Andy_Z Offline
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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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#2257837 - 08/06/21 09:58 PM Re: OCC Contact Information Change Tesla
Tesla Offline
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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! smile
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#2257840 - 08/06/21 10:05 PM Re: OCC Contact Information Change Tesla
Andy_Z Offline
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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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#2257841 - 08/06/21 10:06 PM Re: OCC Contact Information Change Tesla
Tesla Offline
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Totally get it! Thanks again and have a great weekend!
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#2257855 - 08/09/21 02:33 PM Re: OCC Contact Information Change Tesla
John Burnett Offline
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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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#2257924 - 08/09/21 09:09 PM Re: OCC Contact Information Change John Burnett
TeamComply Offline
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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
rlcarey Online
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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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#2257986 - 08/10/21 06:43 PM Re: OCC Contact Information Change TeamComply
John Burnett Offline
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Originally Posted by TeamComply
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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#2259464 - 09/09/21 04:53 PM Re: OCC Contact Information Change Tesla
TeamComply Offline
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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
rlcarey Online
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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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#2259474 - 09/09/21 05:41 PM Re: OCC Contact Information Change rlcarey
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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
Larry Offline
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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
rlcarey Online
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#2259701 - 09/14/21 08:05 PM Re: OCC Contact Information Change Tesla
Larry Offline
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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
rlcarey Online
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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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#2260279 - 09/27/21 02:38 PM Re: OCC Contact Information Change rlcarey
TeamComply Offline
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Spanish version is located here, if anyone else is looking for it: https://www.occ.gov/publications-an.../files/equal-housing-lender-spanish.html
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
dottiec Offline
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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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#2260283 - 09/27/21 03:25 PM Re: OCC Contact Information Change dottiec
John Burnett Offline
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Originally Posted by dottiec
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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