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Today is: September 19, 2024  
 

 

BCG Monthly Newsletter

Bankers’ Compliance Group® is pleased to provide its members with a monthly online Newsletter that keeps members informed on current topics related to Dodd-Frank Regulatory Reform, Consumer Finance, Operations, Commercial Lending, etc. BCG members can view the current Newsletter by selecting the download button below.
 

September 2024 Newsletter Highlights    Download Newsletter  

Fannie, Freddie Extend Reconsideration of Value Policy Effective Date to End of October

As previously reported in the May BCG Newsletter, on May 1, 2024, the FHFA and FHA jointly unveiled new appraisal bias policies.  These policies are intended to provide borrowers with the right to request a reconsideration of value, essentially allowing them to appeal an appraisal valuation if they believe it is inaccurate or the result of bias.

FDIC Proposes to Again Revise Deposit Broker Rule

On July 30, 2024, the FDIC announced a proposed rulemaking to amend the FDIC rule on brokered deposits (12 CFR 337.6).  According to the FDIC, in light of its experience since the adoption of the 2020 brokered deposit final rule and the large bank failures in 2023, the proposed revisions seek to strengthen the safety and soundness of the banking system.

Texas Court Holds CFPB’s Section 1071 Rule (Small Business Lending Data Collection) is Valid But Entertains a New Challenge

Dodd-Frank Act Section 1071 (Section 1071) introduced data collection require-ments for small business lending under the Equal Credit Opportunity Act (ECOA), specifically in ECOA Section 704B (15 USC 1691c-2).  On March 30, 2023, the CFPB issued a final rule to implement Section 1071, known as the Small Business Lending Data Collection Rule (SBLR).  88 FR 35150. 

Commercial Lending Q&A – New Fair Appraisal Rules and Guidance

Question:  Recently, the federal banking agencies have published a number of new fair appraisal rules and guidance (discussed in more detail below).  Do any of these new requirements apply to commercial-purpose loans?

FDIC and NCUA Address Fair Hiring in Banking Act

Under federal law, individuals with convictions for certain types of criminal offenses in their background are generally prohibited from participating in the affairs of insured depository institutions and federally-insured credit unions (FICUs) without the consent of the FDIC or NCUA, as applicable.  

 

Table of Contents

CONSUMER FINANCE

  • Fannie, Freddie Extend Reconsideration of Value Policy Effective Date to End of October
  • CFPB Faces Renewed Challenge to the Constitutionality of its Funding Structure
  • CFPB Files Amicus Brief Claiming “Pay-to-Pay” Fees are “Junk Fees”

BANKING OPERATIONS & FINTECH

  • FDIC Proposes to Again Revise Deposit Broker Rule
  • FTC Final Rule Prohibits Fake Reviews  and Testimonials
  • Federal Court Rules Against Google in Antitrust Case
  • Proposed Amendment to EFTA Would Shift Consumer Wire Liability to Financial Institutions
  • FDIC Releases New Signage Rule FAQs

COMMERCIAL LENDING

  • Texas Court Holds CFPB’s Section 1071 Rule (Small Business Lending Data Collection) is Valid But Entertains a New Challenge
  • CFPB Updates Filing Instruction Guide for the Section 1071 Rule (Small Business Lending Data Collection)

COMMERCIAL LENDING Q&A

  • Commercial Lending Q&A – New Fair Appraisal Rules and Guidance

CORPORATE GOVERNANCE

  • FDIC and NCUA Address Fair Hiring in Banking Act

 

 
 
 

 

 

 

* Janet Bonnefin is retired from the practice of law with the firm.
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