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The OCC, Federal Reserve, FDIC, Farm Credit Administration and the National Credit Union Administration have issued their final rule stating the circumstances under which lenders are required to accept private flood insurance in satisfaction of federal flood insurance coverage requirements. The rule became effective July 1, 2019.
For more information, please click here to view the Compliance Bulletin.
On July 9, 2019, the OCC, Federal Reserve, FDIC, Commodity Futures Trading Commission and the SEC finalized a rule implementing provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA), that exempts certain institutions from application of the Volcker Rule. The rule exempts community banks and their controlling entities with $10 billion or less in total consolidated assets, and total trading assets and liabilities equal to five percent or less of total consolidated assets, from the application of the Volcker Rule.
Ask Your Lawmaker to Co-Sponsor Important Legislation to Delay the Implementation of CECL
The Financial Accounting Standard Board’s new Current Expected Credit Loss standard poses significant operational challenges for the banking industry. CECL, which goes into effect January 2020 for some banks and later for others, will change the economics of lending and the unintended consequences are likely to result in changes to credit availability, product mix and cost of credit, particularly for consumers and small businesses. CECL will change the way your bank accounts for credit/loan losses.
On the eve of the 85th anniversary of the Federal Credit Union Act’s enactment, new research released today found that credit unions are falling short of their mission to serve households of “small means.” In fact, according to the research by respected analyst Karen Shaw Petrou, credit union members are disproportionately from middle- and upper-income households, and credit unions’ lack of “mission compliance” deepens U.S. economic inequality.
Do you need help navigating the regulatory and supervisory system in support of your business model or involvement with financial technologies? SF Fed Navigate fintech analysts can assist.
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Last week CBA reported on the enactment of our sponsored measure Assembly Bill 1393, which extends important tax relief on the forgiveness of mortgage debt by conforming California law to federal law for the 2013 tax year. Please see CBA’s analysis of the bill for more information.
A California appellate court found an employer liable to pay the reasonable costs of its employees’ cell phone bills if use of their phones was necessary to discharge their duties. This outcome does not depend on whether an employee’s phone plan includes limited or unlimited minutes. The case, Cochran v. Schwan’s Home Service Inc., was a class action suit. See CBA’s Regulatory Compliance Bulletin for more information.
AB 1770 seeks to address situations where a lender fails to close a HELOC prior to close of escrow, which may result in the innocent buyer and new lender inheriting the underlying loan and lien. The bill creates a new form “Borrower’s Instruction to Suspend and Close Equity Line of Credit” that, when signed by the borrower and delivered to the lender, instructs the lender to suspend the line of credit for at least 30 days. If the borrower also satisfies the payoff demand, then the lender must close the line and release or reconvey the property.
A new bill, SB 898, allows banks to divulge to the State Treasurer’s Office certain information related to accounts held by state agencies and departments. The purpose of the bill is to help the treasurer’s office to monitor state monies not deposited within the centralized state treasury system. See CBA’s Regulatory Compliance Bulletin for more information.
The financial regulatory agencies have issued a proposed rule to implement a section of S.2155 that grants an exemption from the Volcker rule for community banks that meet certain qualifications; for instance, banks that have $10 billion or less in total consolidated assets as well as trading assets and liabilities of 5 percent or less of total consolidated assets.