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#1822109 - 06/10/13 08:10 PM Dodd Frank for non-small bank
mledesma Offline
New Poster
Joined: Apr 2013
Posts: 16
North East
I'm so new and confused that I need either your help or a gun!

We're not a small bank (over 175 million in assets), and CFPB keep sending updates for small entities.

Should we suppose to follow those guidelines? Or is any other Regulator issuing mid-size bank’s guidelines?

http://files.consumerfinance.gov/f/20130...sation-rule.pdf
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#1822117 - 06/10/13 08:22 PM Re: Dodd Frank for non-small bank mledesma
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
To the CFPB, any bank under 10 Billion is a small entity. Also, you are considered a small entity for other purposes if your asset size is under 1 Billion.

If you are on the general email/blog recipient list, you are getting the same things that everyone else is (large or small). To my knowledge they don't have a separate list of small, medium, and large banks. This is the best guidance you will find short of actually reading the rules themselves...and even this guidance tells you it is not a substitute for reading the actual rules.

As far as the different rules, you will need to follow them all unless you meet any of the exemptions listed within the rules. For the comp rule, there is no exemption based on asset size.
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#1822149 - 06/10/13 09:18 PM Re: Dodd Frank for non-small bank mledesma
mledesma Offline
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Joined: Apr 2013
Posts: 16
North East
Thank you Dani.
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