Capitol Comments
November 2013
When there is a deadline associated with an item, you will see this graphic:
Recent News
Agencies request comments on proposed diversity standards
The Dodd-Frank Act requires each of the federal financial regulatory agencies to have an
Office of Minority and Women Inclusion to address the agency's diversity policies and
practices and to develop standards for assessing diversity policies and practices in their
regulated entities. The agencies proposed joint standards1 for assessing these policies
and practices.
Comment: Although the proposal takes into account individual entities' circumstances,
including asset size, number of employees, and number of customers, the standards in the
proposal appear to suggest that entities that are exempt from Affirmative Action adopt
standards that are very similar to Affirmative Action. Implementing these standards at
small community banks, where management struggles to hire and retain qualified staff,
will be difficult. Community banks are encouraged to comment on proposed joint
standards for assessing diversity policies and practices. When drafting your comment
letter, please refer to the specific inquiries made by the agencies, which begin on page 21
of the document linked above.
CFPB releases new online tool dubbed eRegulations
The CFPB has released a new online tool dubbed eRegulations2, a central resource to
allow users to find answers to questions about regulations.
The new rules on international money transfers, which took effect on October 28, 2013,
are the first rules the CFPB rolled out on eRegulations. The CFPB is seeking comments
and suggestions via email to further enhance the resource.
Comment: It has been suggested that the eRegulations include an option to view an entire
regulation at once. The CFPB responded promptly to that suggestion stating that they
don't currently have a method for viewing a regulation in its entirety, but they are
working on it.
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Agencies issue statement on risks of only offering Qualified Mortgages
In response to lender concerns that making non-Qualified Mortgages would open them
up to liability under the disparate impact doctrine of the Equal Credit Opportunity Act
and Regulation B, regulatory agencies (CFPB, OCC, FRB, FDIC and NCUA) issued a
joint statement last week, addressing the risks of offering only Qualified Mortgages. In
the statement, the agencies said they "do not anticipate that a creditor's decision to offer
only Qualified Mortgages would, absent other factors, elevate a supervised institution's
fair lending risk."
The statement goes on to say that lenders need to continue their current evaluation
processes for fair lending risk as they would for any other product and that each case
will be evaluated on its merits.
Comment: This isn't the unequivocal statement lenders may have hoped for, but there is
some degree of solace in knowing that the regulators do not consider the mere act of
making only Qualified Mortgages a fair lending risk. The “absent other factors” hedge in
the regulators’ statement is the kind of thing that keeps bankers and their lawyers up at
night.
CFPB’s first step toward considering debt collection rules
A CFPB news release3 announced that the CFPB took the first step toward considering
consumer protection rules for the debt collection market. Through its Advance Notice of
Proposed Rulemaking4, the CFPB is collecting information on a wide array of issues,
including the accuracy of information used by debt collectors, how to ensure consumers
know their rights, and the communication tactics collectors employ to recover debts.
The CFPB also announced today that it will begin adding consumer complaints about
debt collections to its public Consumer Complaint Database.5
Comment: The CFPB has issued sample letters consumers can use in dealing with debt
collectors. And the CFPB’s interactive online tool, Ask CFPB6, contains more than 80
questions and answers related to the topic of debt collection. Interestingly, the Q&A
about who is a debt collector includes “attorneys” who are specifically exempted from the
Federal Fair Debt Collection Practices Act so long as they didn’t engage in certain
activities. Is the CFPB bootstrapping attorneys into their regulation of debt collectors
through UDAP?
Director Cordray requests public input on the debt collection industry
CFPB director Richard Cordray published an open letter to the public announcing that
the CFPB has partnered with RegulationRoom7 to provide an easier method for the
public to provide comments.
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CFPB updates countries that qualify for exception to remittance rule
The CFPB published an update to the safe harbor list8 of countries that qualify for an
exception to the Bureau’s remittance rule in the Federal Register. The list is unchanged
from the list first released in September 2012.
Comment: As it relates to this notice, a permanent exception in the Final Rule permits
estimates of certain disclosures when, among other circumstances, a remittance transfer
provider cannot determine the exact amounts it must disclose at the time the disclosures
are required because the laws of the recipient country do not permit such determinations.
The current list of countries and other areas contains: Aruba, Brazil, China, Ethiopia and
Libya.
CFPB provides resources for understanding remittance rule
The Reg. E amendments on foreign remittance were effective as of October 28, 2013, as
subpart B of Regulation E. The amendments provide new protections, including
disclosure requirements, and error resolution and cancellation rights, to consumers who
send remittance transfers to other consumers or businesses in a foreign country. The
amendments implement statutory requirements set forth in the Dodd-Frank Act. This
CFPB webpage9 contains the rule and resources to help consumers understand the rule
and its implications, as well as links to the CFPB’s consumer education resources.
The CFPB also launched a nationwide multimedia campaign10 to inform consumers who
send money internationally about new protections that go into effect. The protections
are contained in a rule that was finalized earlier this year.
Comment: This resource may be helpful to bankers and customers alike. The CFPB
remittance webpage has customer brochures.
FDIC webinar on lending in native communities
The FDIC's Division of Depositor and Consumer Protection Community Affairs Branch
will host a webinar titled Lending in Native Communities: From Opportunity to Success
on November 22, 2013, from 2:00 p.m. to 3:00 p.m. (CST). This webinar will include
examples of successful bank efforts to expand economic inclusion and lending in Native
American, Alaska Native, and Hawaiian American communities. This is the fifth in a
series of webinars highlighting strategies institutions can use to promote community
development and expand access to the banking system. FIL- 53-201311. Click here12 to
register.
Comment: Blacks, Hispanics and Native Americans are the most likely Americans to be
underbanked. The unbanked population includes about 17 million adults, with 21.7
percent black, 19.3 percent Hispanic, and 15.5 percent Native American.
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OCC issues risk management guidance on third-party relationships
The OCC issued Bulletin 2013-2913 providing guidance for assessing and managing risks
associated with business arrangements between banks and other entities. Banks must
practice effective risk management with all activities whether performed by bank
employees or through third parties.
The responsibility of the board and senior management—to ensure that all activities
comply with applicable laws—and are performed safely and soundly, are the same
whether the activities are performed by bank staff or third parties.
Comment: Director Cordray told the Banking, Housing, and Urban Affairs Committee
that the good guys in debt collection are undercut by those without scruples. The CFPB’s
major concerns are (1) accuracy of information regarding the debts and (2) how people
are being treated. He said that people should pay their debt, but that failure to pay a debt
is not a reason for mistreatment.
Interagency guidance related to troubled debt restructurings
The federal bank regulatory agencies issued supervisory guidance14 for financial
institutions addressing certain issues related to the accounting treatment and regulatory
credit risk grade or classification of commercial and residential real estate loans that
have undergone troubled debt restructurings (TDRs). The document reiterates key
aspects of previously issued regulatory guidance and discusses the definition of
collateral-dependent loans and the circumstances under which a charge-off is required
for TDRs. The guidance for these two concepts is included to provide further
clarification and ensure consistent treatment.
Comment: The agencies encourage financial institutions to work constructively with
borrowers and view prudent modifications as positive actions when they mitigate credit
risk. The agencies generally will not criticize financial institutions for engaging in
prudent workout arrangements, even if the modified loans result in adverse credit
classifications or constitute TDRs.
FinCEN announces MOU with Mexico
To enhance and reinforce coordination with Mexican authorities on a variety of
operational and regulatory anti-money laundering initiatives, FinCEN Director Jennifer
Shasky Calvery and Mexico’s National Banking and Securities Commission President
Jaime Gonzalez Aguade have signed an unprecedented Memorandum of Understanding
(MOU) that strengthens their ability to fight transnational financial crime. The MOU
facilitates the exchange of supervisory information in support of both agency’s antimoney laundering and combating terrorist financing (AML/CTF) missions. It also
provides for strict controls and safeguards to ensure that shared information is well
protected and used in a confidential and authorized manner for AML/CTF supervision
purposes only.
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Comment: This is the first time FinCEN has entered into a relationship with another
regulatory body outside the U.S. to share supervisory information related to anti-money
laundering and to combat terrorist financing.
FDIC updates Money Smart Podcast Network website
The FDIC announced15 the launch of an updated English version of the Money Smart
Podcast Network website. The portable audio (MP3) version of the award-winning
Money Smart financial education curriculum is suitable for use with virtually all MP3
players so that consumers of all ages can learn to make informed and prudent financial
decisions while "on the go."
The contents of the revised Money Smart Podcast Network includes updates to reflect
changes in consumer laws, and is in alignment with the Financial Literacy and
Education Commission's (FLEC) "My Money Five." These are the five key principles to
help individuals make sound financial decisions. The podcast also provides a venue for
consumer feedback. Through interactive conversations between talk-show hosts Darryl
and Terry and various guests throughout the podcast, the Money Smart Podcast
Network continues to be a tool to help unbanked and underbanked.
Comment: Money Smart is a comprehensive financial education curriculum designed to
help low- and moderate-income individuals outside the financial mainstream enhance
their financial skills and create positive banking relationships. There are programs
aimed at adults, youth, older adults, and small businesses. There are also Train-theTrainer videos on YouTube designed to train Money Smart instructors.
OCC: Interagency guidance on federal benefit garnishment
The OCC issued CA 13-1616 announcing that the Task Force on Consumer Compliance of
the Federal Financial Institutions Examination Council approved interagency
examination procedures for the Garnishment of Accounts Containing Federal Benefit
Payments Rule17 (Garnishment Rule).
Earlier this year, the Department of the Treasury, the Social Security Administration,
the Department of Veteran Affairs, the Railroad Retirement Board, and the Office of
Personnel Management issued the Garnishment Rule to implement statutory
restrictions on garnishment of certain exempt federal benefit payments. The rule, 31
CFR Part 212, establishes procedures that a financial institution must follow when it
receives a garnishment order against an account holder who receives certain Federal
benefit payments by direct deposit. The examination procedures provide a narrative
discussion of the Garnishment Rule and procedures for examiners to follow in
evaluating an institution’s compliance with the rule.
Comment: Under the regulation, generally, financial institutions that receive a
garnishment order are required to follow certain procedures, including: (1) determining
whether any account held by the named account holder received exempt Federal
payments by direct deposit; (2) determining the sum of protected Federal benefits
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deposited to each individual account during a two-month period; and (3) ensuring that
the account holder has access to an amount equal to that sum or to the current balance of
such account(s), whichever is lower. Federal benefit payments include Social Security;
Supplemental Security Income; Veterans; Federal Railroad retirement, unemployment
and sickness; Civil Service Retirement System; and Federal Employee Retirement System.
Interagency exam procedures for Reg. E
The Federal Reserve issued CA 13-1718 announcing that the Task Force on Consumer
Compliance of the Federal Financial Institutions Examination Council has approved
interagency examination procedures for Regulation E.19 The revised procedures
supersede the Regulation E interagency examination procedures transmitted with CA
10-12.
The procedures incorporate the CFPB’s addition of remittance transfer provisions into a
new Subpart B of Regulation E. Additionally, the procedures are updated to reflect
elimination of the requirement that a fee notice be posted on or at automated teller
machines in section 12 CFR 1005.16, leaving in place the requirement for a specific fee
disclosure to appear on the screen of that machine or on paper issued from the machine.
Fed announces prices for services
The Federal Reserve has approved the private sector adjustment factor20 (PSAF) for
2014 of $23.4 million and the 2014 fee schedules for Federal Reserve priced services
and electronic access. These actions were taken in accordance with the requirements of
the Monetary Control Act of 1980, which requires that, over the long run, fees for
Federal Reserve priced services be established on the basis of all direct and indirect
costs, including the PSAF.
Comment: Forward this to the bank’s CEO and CFO.
Fed’s indexing of amounts used to determine reserve requirements
The Federal Reserve Board announced21 the annual indexing of the amounts used in
determining reserve requirements of depository institutions and deposit reporting
panels effective in 2014.
All depository institutions must hold a percentage of certain types of deposits as
reserves in the form of vault cash, as a deposit in a Federal Reserve Bank, or as a deposit
in a pass-through account at a correspondent institution. Reserve requirements
currently are assessed on the depository institution's net transaction accounts (mostly
checking accounts). Depository institutions must also regularly submit reports of their
deposits and other reservable liabilities.
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FHFA restricts lender-placed insurance practices
The FHFA announced22 that it has directed Fannie Mae and Freddie Mac to prohibit
servicers from being reimbursed for expenses associated with captive reinsurance
arrangements. The announcement follows a Notice that FHFA published in the Federal
Register last March regarding its views on these lender-placed insurance practices and
accepting public input. The Notice also cited concerns that the practices expose Fannie
Mae and Freddie Mac to potential losses as well as litigation and reputation risks.
Fed: Processes for developing scenarios for stress testing
The Federal Reserve Board issued a final policy statement23 describing the processes it
will use to develop scenarios for future capital planning and stress testing exercises.
The policy statement will be used to develop scenarios for both annual supervisory and
company-run stress tests. It describes the characteristics of the stress test scenarios and
explains the procedures for formulating the scenarios. Although the policy statement is
not effective until January 1, 2014, the macroeconomic scenarios released last week for
the 2014 stress testing exercise are consistent with the policy statement.
CFPB guidance for HOEPA-required list of housing counselors
The 2013 HOEPA Final Rule requires lenders to provide applicants for federally-related
mortgages with a written list of HUD-approved housing counseling agencies. A CFPB
issued bulletin (2013-1324) provides guidance to lenders with regard to this requirement.
According to the bulletin, a lender may fulfill the requirement in one of two ways: the
lender may obtain the lists through the CFPB website; or, the lender may generate lists
by independently using the same HUD data the CFPB uses on HUD-approved
counseling agencies—in accordance with the CFPB’s list instructions. The Bureau
published an interpretative rule25 on November 8, 2013, which provides the list
instructions and clarifies how lenders may generate their own lists.
Comment: Entering some rural Zip Codes shows that the nearest HUD approved housing
counselors are over an hour and a half away. Fortunately lenders only have to provide
applicants for federally-related mortgages with a list of counselors. The odds that an
applicant will take a 90-minute drive to visit a counselor are slim. Maybe they’ll get
counseling online or by telephone.
OCC standards on independent consultants
The OCC published standards governing the use of independent consultants in
enforcement actions involving significant violations of law, fraud, or harm to
consumers. OCC 2013-3326
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The standards describe the criteria the OCC will use in determining whether the agency
would require a national bank or federal savings association to retain a consultant, as
well as the institution’s obligation to exercise due diligence to ensure the consultant has
sufficient independence, capacity, resources, and expertise. The guidance clarifies how
the OCC will determine whether the contracts and work plan adequately address
agency’s supervisory concerns. Finally, the standards describe the process for reviewing
consultant qualifications and the contractual terms for the engagement, as well as the
appropriate oversight of the consultant’s performance.
Comment: This is mostly aimed at Wall Street where the relationship between
consultants and financial institutions can be cozy. The guidance applies to consultants
hired when there is an enforcement action that involves significant violations of the law,
fraud, or harm to consumers. It doesn’t apply to consultants hired at the instruction of
the OCC to provide expertise to correct operational or management deficiencies.
FDIC releases economic scenarios for stress testing
FDIC released the economic scenarios27 that will be used by certain financial institutions
with total consolidated assets of more than $10 billion for stress tests required under the
Dodd-Frank Act.
The baseline, adverse, and severely adverse scenarios include key variables that reflect
economic activity, including unemployment, exchange rates, prices, income, interest
rates, and other salient aspects of the economy and financial markets.
The baseline scenario represents expectations of private sector economic forecasters.
The adverse and severely adverse scenarios are not forecasts, rather, they are
hypothetical scenarios designed to assess the strength and resilience of financial
institutions and their ability to continue to meet the credit needs of households and
businesses under stressed economic conditions.
Stress-test reporting template and documentation for banks over $10B
The FDIC issued notice28 to describe the reports and information required to meet the
reporting requirements under Section 165(i)(2) of the Dodd-Frank Act for covered
banks with total consolidated assets between $10 billion and $50 billion.
Comment: The data collected through these templates will be used to assess the
reasonableness of the covered bank's stress-test results and provide forward-looking
information to the FDIC regarding a covered bank's capital adequacy.
CFPB blog entries

Know your financial adviser29
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
You can submit a payday loan complaint30

What military families should know about payday loans31

Your chance to weigh in on debt collection practices32

Preventing illegal discrimination in auto lending33 In March, the CFPB released a
bulletin to help lenders that offer auto loans through dealerships make sure they
are following the law. That bulletin explained that “dealer markup” policies that
give dealerships discretion in what interest rates to charge consumers and that
create incentives for charging higher interest rates may be implemented in a way
that violates the law.

Here’s how community-based organizations can do business with us34

Managing someone else’s money35 (Four booklets to assist agents under powers
of attorney, court-appointed guardians, trustees, and government fiduciaries (SS
representative payees and VA fiduciaries).

Developing standards for assessing diversity policies36

Sending money abroad with more confidence37

Does your college help you know before you owe38

Trick-or-treating for your money39

Making regulations easier to use40
Publications, reports, studies, testimony & speeches
Comptroller Handbook revisions and rescissions: “Insider Activities”
The OCC issued the “Insider Activities41” booklet of the Comptroller’s Handbook. This
updated booklet replaces a similarly titled booklet issued in March 2006.
Comment: Major updates include the following:
•2006 changes to Regulation O (12 CFR 215) reporting requirements.
•Certain Dodd-Frank Act provisions, including
◦section 614 amendment to 12 USC 375b regarding the definition of “extension of
credit” to include credit exposures arising from a derivative transaction (as
defined in 12 USC 84(b)), repurchase agreement, reverse repurchase agreement,
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securities lending transaction, or securities borrowing transaction between the
bank and the insider.
◦section 615 amendment to 12 USC 375 regarding “limitations on purchase of
assets to insiders” (now 12 USC 1828(z)).
◦technical amendment to 12 CFR 215 to implement section 312(b)(2)(A) of DoddFrank. 12 CFR 215.12 states that the requirements of 12 CFR 215 apply to savings
associations (and any subsidiary of a savings association) in the same manner
and to the same extent as if the savings association were a member bank.
•Insider-related statutory or regulatory requirements for federal savings associations.
Comptroller Handbook revisions and rescissions: “Qualified Thrift Lender”
The OCC issued today the “Qualified Thrift Lender” booklet42, which is new to the
Comptroller’s Handbook. This booklet rescinds section 270, “Qualified Thrift Lending
Test,” issued June 2002 as part of the Office of Thrift Supervision’s Examination
Handbook. Qualified Thrift Lender Worksheet43.
OCC online newsletter addresses investing in wind energy projects
The OCC published an online newsletter44 that provides information showing how
national banks and federal savings associations can use public welfare investment
authority to invest in wind energy projects. The online newsletter describes how banks
and thrifts, with the requisite credit, legal, and accounting expertise, may use the public
welfare investment authority to invest in wind energy facilities that create jobs in lowand moderate-income communities, government targeted areas for revitalization, and
rural underserved or distressed middle-income communities.
Comment: Topics include: State of the Wind Market; U.S. Department of Energy
Programs Support Wind Energy; Financing Community-Scale Wind Energy Projects;
How ‘Green’ Investments May Qualify for CRA Consideration; and Using the Public
Welfare Investment Authority to Make Wind Energy Investments.
Guidance on security classification
The OCC, the Federal Reserve, and the FDIC, (collectively, the agencies) issued a joint
Agreement45 to depository institutions to revise the 2004 Uniform Agreement on the
Classification of Assets and Appraisal of Securities Held by Banks and Thrifts (2004
Agreement). These revisions replace references to credit ratings with alternative
standards of creditworthiness consistent with sections 939 and 939A of the Dodd-Frank
Act.
The Agreement applies creditworthiness standards adopted in 2012 to the classification
of securities and removes the reliance on credit ratings as a determinant of
Classification. Specific examples are illustrated to demonstrate the appropriate
application of these standards to the classification of securities. This Agreement should
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be used by depository institutions to assist and facilitate the classification of investment
securities.
FFIEC: A Guide to CRA Data Collection and Reporting
The Guide46 is a resource for assisting in CRA data collection and reporting. It provides
a summary of responsibilities and requirements, directions for assembling the necessary
tools, and instructions for reporting CRA data.
Comment: Send this to your CRA officer. The guide relates only to the collection,
maintenance, and reporting of small business loans, small farm loans, and community
development data as well as the collection, maintenance, and reporting of other
applicable loan data (except data on home mortgage loans) that may be considered
during CRA evaluations.
FedFlash for November
The November updates47 include: New webinar for Account Management Information and
Accounting Information Services data file changes; New FedReturn; Federal Reserve Banks to
publish new FedReceipt RTNs; Reminder – Check Adjustments offers special webinar pricing;
Reminder – Holiday currency; and Announcing 2014 Federal Reserve Financial Services fees.
Fed issues latest FedFocus
FedFocus48 provides the latest Federal Reserve Financial Services news. Each edition
keeps you informed about hot topics in the industry, as well as provides insight into the
value of Federal Reserve Financial Services. The November edition of FedFocus includes
these topics: Technology delivering faster, more efficient processing; FedPayments
Reporter; and Planning your 2014 FEDucation strategy.
HUD announces release of housing scorecard
HUD and Treasury released the October edition of the Obama Administration's Housing
Scorecard – a comprehensive report on the nation’s housing market. The latest data
show important progress across many key indicators—as home prices, purchases of new
homes, and sales of existing homes continue to show strong annual gains—although
officials caution that the overall recovery remains fragile. The full Housing Scorecard is
available online at www.hud.gov/scorecard.
Agency rulemaking:
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Selected final rules since last Capitol Comments:
Homeownership Counseling Organizations Lists Interpretive Rule49
This rule describes data instructions for lenders to use in complying with the
requirement under the High-Cost Mortgage and Homeownership Counseling
Amendments to the Truth in Lending Act (Regulation Z) and Homeownership
Counseling Amendments to RESPA Final Rule to provide a homeownership counseling
list using data made available by the CFPB or HUD.
Selected federal rule proposals with open comment
periods:
FDIC: Restrictions on Sales of Assets of a Covered Financial Company
by the Federal Deposit Insurance Corporation50 The FDIC proposed a rule to
implement a section of the Dodd-Frank Act. Under the section, individuals or entities
that have, or may have, contributed to the failure of a “covered financial company”
cannot buy a covered financial company's assets from the FDIC. This proposed rule
establishes a self-certification process that is a prerequisite to the purchase of assets of a
covered financial company from the FDIC. Comments close on January 6, 2014.
Five Agencies propose rules on loans in areas having Special Flood
Hazards51 The OCC, FRB, FDIC, FCA, and NCUA (collectively, the Agencies) are
proposing to amend their regulations regarding loans in areas having special flood
hazards to implement provisions of the Biggert-Waters Flood Insurance Reform Act of
2012. Specifically, the proposal would establish requirements with respect to the escrow
of flood insurance payments, the acceptance of private flood insurance coverage, and the
force-placement of flood insurance. The proposal also would clarify the Agencies’ flood
insurance regulations with respect to other amendments made by the Act and make
technical corrections. Furthermore, the OCC and the FDIC are proposing to integrate
their flood insurance regulations for national banks and Federal savings associations
and for State non-member banks and State savings associations, respectively.
Comments must be received by December 10, 2013. (The government shutdown has
affected the Office of Federal Register.) FIL-48-201352.
Comment: Highlights of the proposal: The proposal would generally require regulated
lending institutions, or servicers acting on their behalf, to escrow premiums and fees for
flood insurance for any loans secured by residential improved real estate or a mobile
home, unless the institutions qualify for the statutory exception. The proposal would also
require that regulated lending institutions accept private flood insurance that meets the
statutory definition to satisfy the mandatory purchase requirement. The proposal
requests comment on whether the Agencies should accept policies that don’t meet the
FDPA definition of private flood insurance and what the Agencies might require for such
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a policy. The proposal includes new and revised sample notice forms and clauses. One of
the new sample notice forms is Notice of Requirement to Escrow for Outstanding Loans to
inform borrowers of the new escrow requirement. The proposal would amend the forceplacement provisions to clarify that a lender or servicer has authority to charge for flood
insurance on the date coverage lapses or becomes insufficient.
Selected federal proposed rulemaking with closed
comment periods—final rule not yet issued:
HUD proposes “Qualified Mortgage” definition53 HUD proposed a rule to define
a ‘Qualified Mortgage (QM)’ that would be insured, guaranteed or administered by
HUD, including single-family forward mortgages insured by the Federal Housing
Administration (FHA). HUD is seeking the public’s comment on its proposed rule by
October 30th. Read HUD’s proposed rule. There is a technical error in the rule as
published in the Federal Register. HUD will publish a technical correction in the Federal
Register at the earliest possible date. The corrected rule along with the rule's Regulatory
Impact Analysis can be found here. Comments were due by October 30, 2013.
Six agencies repropose risk retention rule54 This proposal was issued jointly by
the Fed, HUD, the FDIC, FHFA, the OCC, and the SEC. The rule would provide assetbacked securities (ABS) sponsors with several options to satisfy the risk retention
requirements. The original proposal generally measured compliance with the risk
retention requirements based on the par value of securities issued in a securitization
transaction and included a so-called premium capture provision. The agencies are now
proposing that risk retention generally be based on fair value measurements without a
premium capture provision. Comments were due on or before October 30, 2013.
Six agencies propose rule to exempt subset of higher-priced mortgage loan
from appraisal requirements - Supplemental Proposal55 The Fed, CFPB, FDIC,
FHFA, NCUA, and OCC issued a proposed rule that would create exemptions from
certain appraisal requirements for a subset of higher-priced mortgage loans. The
proposed exemptions are intended to save borrowers time and money and to promote
the safety and soundness of creditors. The appraisal requirements for higher-priced
mortgages were imposed by the Dodd-Frank Ac. Under the Dodd-Frank Act, mortgage
loans are considered to be higher-priced if they are secured by a consumer's home and
have interest rates above a certain threshold.
The proposed rule would provide that the following three types of higher-priced
mortgage loans would be exempt from the Dodd-Frank Act appraisal requirements:
loans of $25,000 or less; certain "streamlined" refinancing; and certain loans secured by
manufactured housing. Comments were due on or before September 9, 2013.
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CFPB: Proposes Consumer Financial Civil Penalty Fund56 Concurrent with
issuing a final rule, the CFPB also published a proposal and is seeking comments on
possible revisions, adjustments, and refinements to the final rule. The comment period
closed on July 8, 2013.
Comment: Click here57 to learn about the CFPB’s Civil Penalty Fund.
OCC, Fed, FDIC propose clarifications to the Interagency Q&A regarding
CRA58 The OCC, Fed, and FDIC (collectively, the Agencies) are proposing to clarify
their Interagency Questions and Answers Regarding Community Reinvestment to
address several community development issues. Click here59 to see the Agencies’ press
release. Comments closed on May 17, 2013.
CFPB: Proposes integrated Mortgage Disclosures
Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth In
Lending Act (Regulation Z)
Notice of proposed rulemaking
The comment period closed on November 6, 2012.
CFPB: Proposes High-Cost Mortgage and Homeownership Counseling
Amendments to the Truth in Lending Act (Regulation Z) and Homeownership
Counseling Amendments to the Real Estate Settlement Procedures Act (Regulation X).
The comment period closed on September 7, 2012.
Selected upcoming final federal rule
compliance dates:
01.01.2014
FDIC: Interim rule revising risk-based and leverage capital requirements60 The FDIC adopted an
interim final rule that revises its risk-based and leverage capital requirements for FDIC-supervised
institutions. This interim final rule is substantially identical to a joint final rule issued by the OCC
and the Federal Reserve (together, with the FDIC, the agencies).
01.10.2014
CFPB: Amendments to the 2013 Mortgage Rules under the RESPA (Regulation X) and the TILA
(Regulation Z) This rule amends provisions in Regulation Z and final rules issued by the CFPB in
2013, which, among other things, required that consumers receive counseling before obtaining
high-cost mortgages and that servicers provide periodic account statement s and rate adjustment
notices to mortgage borrowers, as well as engage in early intervention when borrowers become
delinquent. The amendments clarify the specific disclosures that must be provided before
counseling for high-cost mortgages can occur, and proper compliance regarding servicing
requirements when a consumer is in bankruptcy or sends a cease communication request under the
Fair Debt Collection Practices Act. The rule also makes technical corrections to provisions of other
rules. The Bureau requests public comment on these changes.
01.01.2014
Fed: Regulatory Capital Rules (Basel III)61 The Fed approved a Basel III final rule. The final rule
minimizes burden on smaller, less complex financial institutions. For more details, refer to the
Federal Reserve’s Press Release62. The FDIC Board of Directors approved an interim final rule63
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that adopts with revisions the three notices of proposed rulemaking (NPRs) that the banking
agencies proposed last year related to Basel III and the standardized approach. The FDIC Board
also approved a joint interagency Notice of Proposed Rulemaking64 to strengthen the
supplementary leverage requirements for the largest most systemically important banking
organizations. The OCC announced (NR 2013-11065) that it approved a final rule revising regulatory
capital rules applicable to national banks and federal savings associations.
01.10.2014
CFPB: Loan Originator Compensation Requirements Under TILA/Regulation Z 66 Amendments to
§1026.36(h) and (i), which are a prohibition on financing credit insurance in connection with
consumer credit transactions secured by a dwelling, and which were to be effective on June 1, 2013,
will now be effective on January 10, 2014 after clarifications are adopted. Click here67 to read the
notice of the delay of the effective date.
01.10.2014
CFPB: RESPA/Regulation X and TILA/Regulation Z Mortgage Servicing68 RESPA final rule
includes servicer’s’ obligations to correct errors asserted by mortgage loan borrowers; provide
certain information requested by such borrowers; and provide protection to such borrowers in
connection with force-placed insurance. The Reg. Z final rule includes initial rate adjustment
notices, periodic statements for residential mortgage loans, crediting of mortgage payments; and
responses to requests for payoff amounts. This final rule was further corrected, clarified, and
amended: CFPB finalizes corrections, clarifications, and amendments to mortgage rules69:
●Clarifies how to determine a consumer’s debt-to-income (DTI) ratio: ●Explains that CFPB’s
RESPA rule does not preempt the field of servicing regulation by states. ●Establishes which
mortgage loans to consider in determining small servicer status. ●Clarifies the eligibility standard
of the temporary QM provision.
01.10.2014
CFPB: Clarifications to the 2013 Mortgage Rules under the Equal Credit Opportunity Act
(Regulation B), Real Estate Settlement Procedures Act (Regulation X), and the Truth in Lending
Act (Regulation Z) Among other things, these amendments: ●Clarify what servicer activities are
prohibited in the first 120 days of delinquency; ●Facilitate servicers’ offering of short-term
forbearance plans; ●Clarify best practices for informing borrowers about the address for error
resolution documents; ●Facilitate lending in rural and underserved areas, while the CFPB is
reexamining the rural and underserved definitions, by: 1) Exempting all small creditors from a new
ban on high-cost mortgages featuring balloon payments so long as certain restrictions are met; and
2) making it easier for certain small creditors to continue to qualify for an exemption from a
requirement to maintain escrows on certain HPMLs; ●Make clarifications about financing of credit
insurance premiums; ●Clarify the definition of a loan originator; ●Clarify the points and fees
thresholds and loan originator compensation rules for manufactured housing employees; ●Revise
effective dates of many loan originator compensation rule provisions.
01.10.2014
CFPB: Ability to Repay (ATR) and Qualified Mortgage (QM) Standards under TILA/Regulation Z 70
01.10.2014
CFPB: High-Cost Mortgage and Homeownership Counseling Amendments to TILA/Regulation Z
and Homeownership Counseling Amendments to RESPA/Regulation X71 implements Dodd-Frank
Act amendments to TILA and RESPA. Expands the types of mortgage loans subject to the
protections of HOEPA, revises and expands the tests for coverage under HOEPA, and imposes
additional restrictions on mortgages that are covered by HOEPA, including a pre-loan counseling
requirement.
01.18.2014
CFPB: Disclosure and Delivery Requirements for Copies of Appraisals and Other Written
Valuations Under ECOA/Regulation B72
o1.18.2014
CFPB, FRB, FDIC, FHFA, NCUA, and OCC: Appraisals for Higher-Priced Mortgage Loans73
Comment: Distribute this calendar to your CEO, CFO, Compliance Officer, and Operations
Officer.
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Selected final federal rule compliance dates from
the past 12 months:
Our list of past final rule effective dates is limited to 12 months. To see the document
“Selected Past Final Federal Rules,” containing final rules with effective dates more than
12 months old, click here.
10.28.2013
CFPB: Final Consumer protection rule on international remittances (Reg. E) This rule was followed
by a clarification: CFPB Final Rule: Clarificatory amendment and technical correction to a final rule
and official interpretation of disclosures for remittance transactions (Reg. E)
11.04.2013
Final rule prohibiting issuing credit card unless ability to make payments is considered (Reg. Z)
10.17.2013
FHA approval of lending institutions and mortgagees: streamlined reporting requirements for
small supervised lenders and mortgagees74 This rule streamlines the FHA financial statement
reporting requirements for lenders and mortgagees who are supervised by federal banking agencies
and whose consolidated assets do not meet the thresholds set by their supervising federal banking
agencies for submission of audited financial statements (currently set at $500 million in
consolidated assets).
09.26.2013
CFPB: Rules of Practice for Issuance of Temporary Cease-and-Desist Orders The Dodd-Frank Act
requires the CFPB to prescribe rules establishing procedures for the conduct of adjudication
proceedings. On June 29, 2012, the Bureau published the final Rules of Practice for Adjudication
Proceedings. That final rule, however, does not apply to the issuance of a temporary cease-anddesist order (TCDO) pursuant to section 1053(c) of the Dodd-Frank Act. The CFPB issued an
interim final rule governing such issuance and seeks public comments. The interim final rule took
effect on September 26, 2013.
07.01.2013
FTC: Amends the Children's Online Privacy Protection Rule (“COPPA Rule” or “Rule”), consistent
with the requirements of the Children's Online Privacy Protection Act, to clarify the scope of the
Rule and strengthen its protections for children's personal information, in light of changes in online
technology since the Rule went into effect in April 2000. The final amended Rule includes
modifications to the definitions of operator, personal information, and Web site or online service
directed to children. The amended Rule also updates the requirements set forth in the notice,
parental consent, confidentiality and security, and safe harbor provisions, and adds a new provision
addressing data retention and deletion. (Comment: Financial institutions are subject to COPPA if
they operate a website or online services directed to children or have actual knowledge that they are
collecting or maintaining personal information from a child online.)
06.01.2013
CFPB: Escrow Requirements for Higher-Priced Mortgages Under TILA/Regulation Z 75 The CFPB
issued Clarifications of the 2013 Escrows final rule76 (Reg. Z) on May 16, 2013.
06.01.2013
Amendments in the Loan Originator Compensation final rules77 to §1026.36 (h) and (i) are effective
on this June 1, 2013. Section 1026.36(h) is regarding the prohibition on mandatory arbitration
clauses and waivers of certain consumer rights. Section 1026(i) is regarding the prohibition on
financing single-premium credit insurance.
03.31.2013
FinCEN: SAR/CTR batch filers must update their systems to the new specifications78. (Extended
from June 30, 2012 to March 31, 201379) All institutions that batch file the current CTR, CTR-C,
SAR-DI, SAR-SF, SAR-MSB, or SAR-C will have to convert their systems to file the new CTR and
SAR. FinCEN will make other filing technical specifications available in the near future.
03.28.2013
In order to resolve litigation regarding a Reg. Z provision limiting fees a consumer must pay prior
to opening a credit card account, the CFPB issued an April 2012 proposal to amend the rule to be
consistent with a court ruling so that it no longer applies to fees charged prior to account opening.
On March 22, the CFPB adopted a final rule80 adopting the proposal’s elimination of the cap on fees
charged prior to account opening.
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03.26.2013
The CFPB amended Reg. E81 to conform to legislation that amended the EFTA to eliminate a
requirement that owners of ATMs post a fee notice on all ATMs. The onscreen notice requirement
remains.
01.01.2013
The IRS final regulations82 regarding the reporting requirements for interest that relates to deposits
maintained at U.S. offices of certain financial institutions and is paid to certain nonresident alien
individuals. These regulations apply to payments of interest made on or after January 1, 2013.
12.31.2012
Housing and Economic Recovery Act by The Helping Heroes Keep Their Homes Act of 2010 – The
provision for an extended time period (extended from 90 days to nine months) for protections
affecting foreclosure, sale, or seizure of servicemembers’ real or personal property expires.
11.30.2012
The Board is amending Regulation D,83 Reserve Requirements of Depository Institutions, to reflect
the annual indexing of the reserve requirement exemption amount and the low reserve tranche for
2013.
10.01.2012
The Federal Reserve Board final rule84 amends the provisions in Regulation II (Debit Card
Interchange Fees and Routing) that permit a debit card issuer subject to the interchange fee
standards to receive a fraud-prevention adjustment. The final rule revises provisions that are
currently in effect as an interim final rule.
How to submit comments to your federal
regulators:
Office of the Comptroller of the Currency: Because paper mail in the Washington, DC area and at the OCC is
subject to delay, commenters are encouraged to submit comments by the Federal eRulemaking Portal or e-mail, if
possible. Please use the title in the Federal Register publication of the proposal. You may submit comments by any of
the following methods:

Federal eRulemaking Portal—Regulations.gov: Go to

http://www.regulations.gov . Select “Document Type” of “Proposed Rule”, and in “Enter Keyword or ID Box”,
enter the docket number found in the Federal Register publication of the proposed rule and click “Search.” On “View
By Relevance” tab at bottom of screen, in the “Agency” column, locate the proposed rule for OCC, in the “Action”
column, click on “Submit a Comment” or “Open Docket Folder” to submit or view public comments and to view
supporting and related materials for this proposed rule.

Click on the “Help” tab on the Regulations.gov home page to get information on using Regulations.gov, including
instructions for submitting or viewing public comments, viewing other supporting and related materials, and viewing
the docket after the close of the comment period.

E-mail: regs.comments@occ.treas.gov

Mail: Office of the Comptroller of the Currency, 250 E Street, SW., Mail Stop 2-3, Washington, DC 20219.

Fax: (202) 874-5274.

Hand Delivery/Courier: 250 E Street, SW., Mail Stop 2-3, Washington, DC 20219.
Instructions: You must include “OCC” as the agency name and the docket number in your comment. In general, OCC
will enter all comments received into the docket and publish them on the Regulations.gov Web site without change,
including any business or personal information that you provide such as name and address information, e-mail
addresses, or phone numbers. Comments received, including attachments and other supporting materials, are part of
the public record and subject to public disclosure.
Do not enclose any information in your comment or supporting materials that you consider confidential or
inappropriate for public disclosure.
Board of Governors of the Federal Reserve System: You may submit comments, identified by the docket
number and the RIN number found in the Federal Register publication of the rule proposal, by any of the following
methods:
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
Agency Web Site: http://www.federalreserve.gov. Follow the instructions for submitting comments at
http://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm.

Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.

E-mail: regs.comments@federalreserve.gov. Include the docket number and RIN number in the subject line of
the message.

Fax: (202) 452-3819 or (202) 452-3102.

Mail: Address to Jennifer J. Johnson, Secretary, Board of Governors of the Federal Reserve System, 20th Street
and Constitution Avenue, NW., Washington, DC 20551.
Federal Deposit Insurance Corporation: You may submit comments, identified by RIN number, by any of the
following methods:

Agency Web Site: http://www.FDIC.gov/regulations/laws/federal/propose.html. Follow instructions for
submitting comments on the Agency Web Site.

E-mail: Comments@FDIC.gov. Include the RIN number on the subject line of the message.

Mail: Robert E. Feldman, Executive Secretary, Attention: Comments, Federal Deposit Insurance Corporation,
550 17th Street, NW, Washington, DC 20429.

Hand Delivery: Comments may be hand delivered to the guard station at the rear of the 550 17th Street Building
(located on F Street) on business days between 7:00 a.m. and 5:00 p.m.
Instructions: All comments received must include the agency name and RIN for this rulemaking and will be posted
without change to
http://www.fdic.gov/regulations/laws/ federal/propose.html, including any personal information provided.
Consumer Financial Protection Bureau: You may submit comments, identified by docket number, by any of the
following methods:


Electronic: http://www.regulations.gov. Follow the instructions for submitting comments.
Mail: Monica Jackson, Office of the Executive Secretary, Consumer Financial Protection Bureau, 1500
Pennsylvania Ave. NW., (Attn: 1801 L Street), Washington, DC 20220.
 Hand Delivery/Courier in Lieu of Mail: Monica Jackson, Office of the Executive Secretary, Consumer
Financial Protection Bureau, 1700 G Street NW., Washington, DC 20006.
Instructions: The CFPB encourages the early submission of comments. All submissions must include the
document title and docket number. Please note the number of the question to which you are responding at the
top of each response (respondents need not answer each question). In general, all comments received will be
posted without change to http://www.regulations.gov. In addition, comments will be available for public
inspection and copying at 1700 G Street NW., Washington, DC 20006, on official business days between the
hours of 10 a.m. and 5 p.m. Eastern Time. You can make an appointment to inspect the documents by
telephoning (202) 435-7275. All comments, including attachments and other supporting materials, will become
part of the public record and subject to public disclosure. Sensitive personal information such as accouni8ik2t
numbers or Social Security numbers should not be included. Comments will not be edited to remove any
identifying or contact information.
Common words, phrases, and acronyms
APOR
CAPITOL
“Average Prime Offer
Rates” are derived from
average interest rates,
points, and other
pricing terms offered by
a representative sample
of creditors for
mortgage transactions
COMMENTS
that have low-risk
pricing characteristics.
ATM
Automated Teller
Machine
N O V E M B E R 2 0 1 3 Page 18
CARD Act
Credit Card
Accountability
Responsibility and
Disclosure Act of 2009
CFPB
Consumer Financial
Protection Bureau
CFR
Code of Federal
Regulations.
Codification of rules and
regulations of federal
agencies.
CRA
Community
Reinvestment Act. This
Act is designed to
encourage loans in all
segments of
communities.
CRE
Commercial Real Estate
CSBS
Conference of State
Bank Supervisors
CTR
Currency Transaction
Report. Filed for each
deposit, withdrawal,
exchange of currency
that involves a
transaction in currency
of more than $10,000.
Dodd-Frank Act
The Dodd–Frank Wall
Street Reform and
Consumer Protection
Act
FFIEC
Federal Financial
Institutions
Examination Council
FHFA
Federal Housing
Finance Agency
FHA
Federal Housing
Administration
FinCEN
Financial Crime
Enforcement Network
FR
Federal Register. U.S.
government daily
publication that
contains proposed and
final administrative
regulations of federal
agencies.
FRB
Federal Reserve Board
FSOC
Financial Stability
Oversight Council
FTC
Federal Trade
Commission
GAO
Government
Accountability Office
HARP
Home Affordable
Refinance Program
HAMP
Home Affordable
Modification Program
FDIC
Federal Deposit
Insurance Corporation
HMDA
Home Mortgage
Disclosure Act
EFTA
Electronic Fund
Transfer Act
HOEPA
Home Ownership and
Equity Protections Act
of 1994
Federal bank
regulatory agencies
FDIC, FRB, and OCC
HPML
Higher Priced Mortgage
Loan
Federal financial
institution regulatory
agencies
CFPB, FDIC, FRB,
NCUA, and OCC
HUD
U.S. Department of
Housing and Urban
Development
FEMA
Federal Emergency
Management Agency
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IRS
Internal Revenue
Service
MLO
Mortgage Loan
Originator
MOU
Memorandum of
Understanding
NFIP
National Flood
Insurance Program.
U.S. government
program to allow the
purchase of flood
insurance from the
government.
NMLS
National Mortgage
Licensing System
OCC
Office of the
Comptroller of the
Currency
OFAC
Office of Foreign Asset
Control
OREO
Other Real Estate
Owned
QRM
Qualified Residential
Mortgage
Reg.
Reg. B
Abbreviation for
“Regulation” – A federal
regulation. These are
found in the CFR.
Reg. C
Home Mortgage
Disclosure
Reg. DD
Truth in Savings
Reg. E
Electronic Fund
Transfers
Reg. G
S.A.F.E. Mortgage
Licensing Act
Reg. P
Privacy of Consumer
Financial Information
Reg. X
Real Estate Settlement
Procedures Act
Reg. Z
Truth in Lending
RESPA
Real Estate Settlement
Procedures Act
SAR
Suspicious Activity
Report – Report
financial institutions file
with the U.S.
government (FinCEN)
regarding activity that
may be criminal in
nature.
SDN
Specially Designated
National
TILA
Truth in Lending Act
TIN
Tax Identification
Number
Treasury
U.S. Department of
Treasury
Equal Credit
Opportunity
This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is
provided with the understanding that the publisher is not engaged in the rendering of legal, accounting or other professional
advice - from a Declaration of Principles adopted by the American Bar Association and a Committee of Publishers and
Associations; All rights reserved; Shannon Phillips Jr., Editor; Oklahoma Edition, copyrighted by Craig Buford, CBAO
President and CEO.
Capitol Comments
November 2013
Craig Buford, CAE
CAPITOL
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N O V E M B E R 2 0 1 3 Page 20
President and CEO
Community Bankers Association of Oklahoma
4101 Perimeter Center Drive, Suite 107
Oklahoma City, OK 73112
Office: 405-524-4122
Cell: 405-833-9499
Fax: 405-524-0443
cbuford@cba-ok.org
www.cba-ok.org
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30
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31
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32
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33
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34
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35
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36
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37
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38
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39
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46
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47
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69
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http://www.consumerfinance.gov/regulations/ability-to-repay-and-qualified-mortgage-standards-under-the-truthin-lending-act-regulation-z/
71
http://files.consumerfinance.gov/f/201301_cfpb_final-rule_high-cost-mortgages.pdf
72
http://www.consumerfinance.gov/regulations/disclosure-and-delivery-requirements-for-copies-of-appraisals-andother-written-valuations-under-the-equal-credit-opportunity-act-regulation-b/
73
http://www.consumerfinance.gov/regulations/appraisals-for-higher-priced-mortgage-loans/
74
https://www.federalregister.gov/articles/2013/09/17/2013-22583/federal-housing-administration-fha-approval-oflending-institutions-and-mortgagees-streamlined
75
http://files.consumerfinance.gov/f/201301_cfpb_final-rule_escrow-requirements.pdf
76
http://files.consumerfinance.gov/f/201305_cfpb_Escrows-Clarifications-final-rule.pdf
77
http://www.consumerfinance.gov/regulations/loan-originator-compensation-requirements-under-the-truth-inlending-act-regulation-z/
78
http://www.fincen.gov/news_room/nr/html/20110902.html
79
http://www.fincen.gov/whatsnew/pdf/20111220.pdf
80
https://www.federalregister.gov/articles/2013/03/28/2013-07066/truth-in-lending-regulation-z
81
https://www.federalregister.gov/articles/2013/03/26/2013-06861/disclosures-at-automated-teller-machinesregulation-e
82
http://www.gpo.gov/fdsys/pkg/FR-2012-04-19/pdf/2012-9520.pdf
83
http://www.gpo.gov/fdsys/pkg/FR-2012-10-31/html/2012-26662.htm
84
http://www.gpo.gov/fdsys/pkg/FR-2012-08-03/pdf/2012-18726.pdf
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