Compliance Bulletin

CBA Submits Comments on Two Favorable Interim Final Rules
May 2, 2016

Last December, Congress enacted a transportation bill (Fixing America’s Surface Transportation Act or FAST Act), and included in the legislation two sections that CBA, working together with other industry representatives, long supported. One is Section 83001, which increases the asset size threshold for allowing banks to have an 18-month examination cycle instead of 12 months. As a result of the legislation, CAMELS 1 or 2 banks with up to $1 billion in assets are eligible for the expanded exam cycle if other criteria are met. The other provision, titled “HELP Rural Communities Act,” increases the number of creditors that are eligible for exemptions from the prohibition against balloon payment loans (under the qualified mortgage rules) and from the requirement to establish escrow accounts for high cost mortgage loans. The responsible federal agencies adopted two interim final rules to implement the provisions of the FAST Act and invited public comments. CBA expressed support for these changes.