CBAI will be submitting two comment letters; this letter regarding the definition of
|
|
- Antony Evans
- 6 years ago
- Views:
Transcription
1 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC Re: Amendments Relating to Small Creditors and Rural and Underserved Areas Under the Truth in Lending Act (Regulation Z) Docket No. CFPB and RIN 3170-AA43 Dear Ms. Jackson: The Community Bankers Association of Illinois ( CBAI ), which represents approximately 380 Illinois community banks and thrifts, appreciates the opportunity to provide our observations and recommendations regarding the Consumer Financial Protection Bureau s ( CFPB or Bureau ) proposed amendments ( Proposed Amendments ) to certain mortgage rules issued in 2013, revising the Bureau s definitions of small creditor, and rural and underserved areas, for purposes of special provisions and exemptions under the CFPB s ability to repay ( ATR ), qualified mortgage ( QM ) underwriting requirements, and escrow requirements for higherpriced mortgage loans ( HPML ). The Bureau is issuing these Proposed Amendments pursuant to its authority under the Dodd-Frank Act ( Dodd-Frank ) and Truth in Lending Act ( TILA ). CBAI will be submitting two comment letters; this letter regarding the definition of The Community Bankers Association of Illinois (CBAI) is dedicated to exclusively representing the interests of Illinois community banks (and many Illinois thrifts) through effective advocacy, outstanding education and high quality products and services. CBAI s 380 members hold over $72 billion in assets, operate in 860 locations statewide and lend to consumers, small businesses and the agricultural community. For more information please visit
2 Page 2 underserved areas and a second letter regarding the proposed definitions of small creditor and rural areas. The Bureau has been granted broad authority under the Dodd-Frank section of TILA which authorizes the Bureau to prescribe residential mortgage rules and that such rules may contain additional requirements, provisions, classifications, definitions, exceptions, revisions, additions/subtractions and adjustments as, in the judgment of the Bureau, are appropriate, necessary and proper to effectuate the purposes of TILA. Based on this broad authority the Bureau created and defined a small creditor (i.e., community banks and thrifts) exemption and exemptions for rural and underserved areas. CBAI recommends that all community bank and thrift loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas, should receive automatic QM status and an automatic exemption from escrow requirements for HPMLs. If the Bureau chooses not to implement our recommendation, then in the alternative, CBAI supports a special accommodation for small creditors which provide these institutions with greater flexibility in serving the needs of their customers, particularly those in rural and underserved areas. In the Proposed Amendments, the Bureau revised the definitions of small creditor and rural areas but unfortunately chose not to revise the definition of underserved areas at this time - believing it is appropriately defined as areas in which the withdrawal of a creditor from the market could leave no meaningful competition for consumer mortgage business. CBAI believes the Bureau has mistakenly chosen a lack of competitors as the sole definitional standard to designate areas as underserved and is missing a valuable opportunity to better serve consumers and communities by not modifying the definition to incorporate additional characteristics of an area. In its comment letter of February 22, 2013, and again on September 22, 2014, CBAI urged the CFPB to consider more than simply the number of competitors in a county in defining an area as underserved and to expand the definition to include economically challenged areas. Many of these areas were devastated by the financial crisis and are being served by nontraditional lenders or those operating in the deep shadows. These lenders have higher costs/risks to consumers, and are not traditional Main Street lenders. Unfortunately, given the current definition, and the Bureau s decision not to revise the definition of underserved areas at this time, areas which
3 Page 3 are economically challenged will not qualify as underserved yet the CBAI believes they truly are. Community banks and thrifts have an outstanding record of responsibly serving all of their customers and communities which will benefit from these institutions expanding their residential mortgage lending efforts. The Bureau recognized the importance of these institutions by highlighting in the Proposed Amendments the role they play in providing mortgage credit to consumers, their (versus larger institutions) better assessing ability to repay, a lending model based on maintaining ongoing relationships with their customers, having a more comprehensive understanding of the financial circumstances of their customers, and a more in-depth understanding of the economic and other particular circumstances of their communities. As with the definition of rural areas, there are dozens of different definitions of economically challenged areas which are used by financial industry regulators and Federal Agencies. Illinois community banks and thrifts are most familiar with the following: low- and moderate-income census tracts for CRA purposes, and distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies for FFIEC purposes. Other economically challenged areas in Illinois and around the country, although this is not a definitive list, include: counties with high poverty rates, qualified, distressed or highly distressed census tracts for New Market Tax Credit Programs, high migration rural counties, designated distressed areas by the Appalachian Regional Commission or the Delta Regional Authority,
4 Page 4 Federally designated Empowerment Zones, Enterprise Zones and Communities, Renewal Communities, U. S. SBA-designated HUB Zones, areas encompassed by a HOPE VI redevelopment plan, Federally designated Native American or Alaska Native areas, Hawaiian Homelands, or redevelopment areas by the appropriate Tribal or other authority, medically underserved areas, state or local tax-incremental financing districts, River Edge Redevelopment Zones, and counties for which the Federal Emergency Management Agency (FEMA) has issued a "major disaster declaration" since July 15, CBAI again urges the Bureau to expand the definition of underserved areas, to include those identified above, which is completely within the discretion of the CFPB under the Dodd- Frank/TILA, while remaining consistent with providing a reasonable exception in the Ability to Repay requirements and Qualified Mortgage rules under the Truth in Lending Act (Reg Z). Community banks and thrifts should be encouraged to serve economically challenged areas, and these communities and consumers will benefit from this special accommodation. If you have any questions or require any additional information, please contact me at
5 Page or at davids@cbai.com. Sincerely, /s/ David G. Schroeder Vice President Federal Governmental Relations Community Bankers Association of Illinois 901 Community Drive Springfield, Illinois 62703
Re: Amendments to the 2013 Escrows Final Rule under the Truth in Lending Act. Regulation Z [Docket No. CFPB ]
May 3, 2013 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Amendments to the 2013 Escrows Final Rule under the Truth in
More informationRe: CFPB Request for Information regarding the Ability-to-Repay/Qualified Mortgage Rule Assessment
July 31, 2017 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1275 First Street, NE Washington, DC 20002 Re: CFPB-2017-0014 Request for Information regarding the Ability-to-Repay/Qualified
More informationJoe Gendron, Director of Government Relations 5555 Bankers Avenue, Baton Rouge, LA (225) ,
Joe Gendron, Director of Government Relations 5555 Bankers Avenue, Baton Rouge, LA 70808 (225) 214-4837, gendron@lba.org February 15, 2013 Comment Letter Ability-to-Repay Standards under TILA Docket No.
More informationCONSUMER CREDIT INDUSTRY ASSOCIATION
CONSUMER CREDIT INDUSTRY ASSOCIATION Scott J, Cipinko 6300 Powers Ferry Road, Suite 600-286 Executive Vice President & CEO Atlanta, Georgia 30339 678.858.4001 sjcipinko@cciaonline.com Ms. Monica Jackson
More informationNovember 6, Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552
November 6, 2012 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Proposed Rule on High-Cost Mortgage and Homeownership
More informationFebruary 25, Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC
Robert R. Davis Executive Vice President Mortgage Markets, Financial Management & Public Policy (202) 663-5588 RDavis@aba.com Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection
More informationAn introduction to the Community Reinvestment Act. John Meeks Atlanta Region FDIC Community Affairs
An introduction to the Community Reinvestment Act John Meeks Atlanta Region FDIC Community Affairs What is the CRA? CRA stands for: The Community Reinvestment Act of 1977 The regulations implementing the
More informationCRA Basics and the Exam Process
CRA Basics and the Exam Process Objectives Upon completion of the CRA overview, you should understand: l Purpose of the CRA l Terms and definitions under the CRA regulation including bank exam types l
More informationSummary of CBA s Comments
June 3, 2013 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2013-0010 Proposed Amendments to the 2013 Mortgage
More informationTestimony of. Kenneth E. Bentsen Jr., Executive Vice President, Public Policy and Advocacy. Securities Industry and Financial Markets Association
Testimony of Kenneth E. Bentsen Jr., Executive Vice President, Public Policy and Advocacy Securities Industry and Financial Markets Association Before the U.S. House Subcommittee on Financial Institutions
More informationOctober 30, Legislative and Regulatory Activities Division Office of the Comptroller of the Currency
October 30, 2013 Robert dev. Frierson, Secretary Board of Governors of the Federal Reserve System 20 th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. R-1411 Robert E. Feldman Executive
More informationTESTIMONY OF MR. JERRY REED CHIEF LENDING OFFICER ALASKA USA FEDERAL CREDIT UNION ON BEHALF OF THE CREDIT UNION NATIONAL ASSOCIATION
TESTIMONY OF MR. JERRY REED CHIEF LENDING OFFICER ALASKA USA FEDERAL CREDIT UNION ON BEHALF OF THE CREDIT UNION NATIONAL ASSOCIATION BEFORE THE SUBCOMMITTEE ON FINANCIAL INSTITUTIONS AND CONSUMER CREDIT
More informationPromoting Investment in Distressed Communities:
CommunityDevelopment Financial Institutions Fund Promoting Investment in Distressed Communities: The New Markets Tax Credit Program UNITED STATES DEPARTMENT OF THE TREASURY PREPARED by Financial Strategies
More informationJune 3, Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street N.W. Washington, D.C.
Robert R. Davis Executive Vice President Mortgage Markets, Financial Management & Public Policy (202) 663-5588 RDavis@aba.com Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection
More informationNational Reverse Mortgage Lenders Association th Street, N.W. Washington, DC 20036
National Reverse Mortgage Lenders Association 1400 16 th Street, N.W. Washington, DC 20036 July 22, 2011 regs.comments@federalreserve.gov Jennifer J. Johnson Secretary, Board of Governors of the Federal
More informationMortgage Lending Compliance Issues Session 1. Higher Priced and High-Cost Mortgages
Mortgage Lending Compliance Issues Session 1 Higher Priced and High-Cost Mortgages Today s Topics Learn the definitions of Higher Priced and High Cost Mortgages and how to test to determine if you are
More informationObjectives Upon completion of the CRA overview, you should:
CRA Basics Objectives Upon completion of the CRA overview, you should: Understand the purpose of the CRA; Understand terms and definitions under the CRA regulation including bank exam types Be generally
More informationSubmitted Electronically. August 14, 2017
Submitted Electronically August 14, 2017 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1275 First Street NE Washington, DC 20002 Re: Request for Comment Regarding
More informationSUMMARY: The Bureau of Consumer Financial Protection (CFPB or Bureau) is publishing this agenda
This document is scheduled to be published in the Federal Register on 06/09/2016 and available online at http://federalregister.gov/a/2016-12931, and on FDsys.gov BUREAU OF CONSUMER FINANCIAL PROTECTION
More informationCRA STRATEGY DEVELOPMENT. Housing Now! Conference October 15, 2015
CRA STRATEGY DEVELOPMENT Housing Now! Conference October 15, 2015 Exam Types Small bank Less than $305 million in assets as of last two year ends Intermediate small bank (ISB) Assets of a least $305 million,
More informationSee 12 U.S. Codes 1021(b)(3), 1022, available at 111publ203/pdf/PLAW-111publ203.pdf. 4
July 31, 2017 Ms. Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 Via electronic submission Re: Response of the Consumer
More informationNotice Regarding Updated Regulations and Summary of Recent CFPB Mortgage Rules
April 23, 2012 Notice Regarding Updated Regulations and Summary of Recent CFPB Mortgage Rules The Consumer Financial Protection Bureau ( CFPB or Bureau ) recently issued final rules related to mortgage
More informationCompliance Challenges in a Changing Economic Environment
Compliance Challenges in a Changing Economic Environment Call the Fed Audio Conference December 10, 2008 The following presentation contains the views and opinions of the speakers and his or her interpretation
More informationSeptember 7, 2012 VIA ELECTRONIC DELIVERY AND HAND DELIVERY
VIA ELECTRONIC DELIVERY AND HAND DELIVERY Monica Jackson Office of the Executive Secretary 1700 G Street, N.W. Washington, D.C. 20552 Re: Docket No. CFPB-2012-0029; RIN3170-AA12; Proposed Rule - High-Cost
More informationRE: Request for Information Regarding Bureau Financial Education Programs (Docket No. CFPB )
Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street NW Washington, D.C. 20552 RE: Request for Information Regarding Bureau Financial Education Programs
More informationNew Lending Opportunities in the Changed Mortgage Market: Dodd-Frank Act Mortgage Regulations
New Lending Opportunities in the Changed Mortgage Market: Dodd-Frank Act Mortgage Regulations Kenneth Benton Senior Consumer Regulations Specialist May 14, 2014 FEDERAL RESERVE BANK OF PHILADELPHIA Disclaimer:
More informationQualified Mortgages and Qualified Residential Mortgages under the Dodd-Frank Act
Qualified Mortgages and Qualified Residential Mortgages under the Dodd-Frank Act Kenneth Benton Senior Consumer Regulations Specialist Greg Bell Banking Supervisor Consumer Compliance Risk Team FEDERAL
More informationRe: Docket ID OCC : Reforming the Community Reinvestment Act Regulatory Framework
LIHTC WORKING GROUP Office of the Comptroller of the Currency Attn: Legislative and Regulatory Activities Division 400 7 th Street SW, Suite 3E-218 Washington, DC 20219 Re: Docket ID OCC-2018-0008: Reforming
More informationOctober 7, Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC
Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552. Cooperative Credit Union Association, Inc. Comments on Proposed Rule Payday,
More informationCOMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE June 2, 2008 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Legacy Bank & Trust Company RSSD # 397755 10603 Highway 32 P.O. Box D Plato, Missouri 65552 Federal Reserve Bank of St.
More informationAppraisals for Higher-Priced Mortgage Loans Exemption Threshold
BILLING CODE: 4810-33-P; 6210-01-P; 4810-AM-P DEPARTMENT OF THE TREASURY Office of the Comptroller of the Currency 12 CFR Part 34 Docket No. OCC-2015-0021 RIN 1557-AD99 FEDERAL RESERVE SYSTEM 12 CFR Part
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE March 2, 2015 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Stifel Bank and Trust RSSD# 3076248 501 North Broadway St. Louis, Missouri 63102 Federal Reserve Bank of St. Louis P.O.
More informationAmendments to Federal Mortgage Disclosure Requirements under the Truth in Lending
BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB-2017-0018] RIN 3170-AA61 Amendments to Federal Mortgage Disclosure Requirements under the Truth in Lending
More informationJune 3, Docket No. CFPB
June 3, 2013 Re: Amendments to the 2013 Mortgage Rules under the Real Estate Settlement Procedure Act (Regulation X) and the Truth In Lending Act (Regulation Z) Docket No. CFPB-2013-0010 The Greenlining
More informationNew Markets Tax Credits
1 New Markets Tax Credits Lecture Notes City of San Antonio Community Development Summit 2009 927 Dudley Road Edgewood, KY 41017 Ph: 859-578-4850 Fax: 859-578-4860 2006 All rights reserved. Version: May
More informationInvestment in Indian Country: How Investments in Tribal Infrastructure and Other Tribal Projects May Qualify for Community Reinvestment Act Credit
Investment in Indian Country: How Investments in Tribal Infrastructure and Other Tribal Projects May Qualify for Community Reinvestment Act Credit By John Mussman, Randolph DelFranco and William Wood Tribal
More informationMortgage Reform Under the Dodd-Frank Act
Mortgage Reform Under the Dodd-Frank Act Kenneth Benton Senior Consumer Regulations Specialist September 20, 2013 FEDERAL RESERVE BANK OF PHILADELPHIA DISCLAIMER: The views expressed are the presenters
More informationAmendments to the 2013 Mortgage Rules under the Truth in Lending Act (Regulation Z)
BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 Docket No. CFPB-2014-0009 RIN 3170-AA43 Amendments to the 2013 Mortgage Rules under the Truth in Lending Act (Regulation
More informationPresentation Topics. Changing Data Requirements Will Effect. Census data update and implications for CRA, HMDA and Fair Lending
Changing Data Requirements Will Effect the CRA and Fair Lending Environment Prepared for the 2012 National Community Reinvestment Conference by Glenn Canner March 28, 2012 The views expressed are those
More informationRecent CFPB Mortgage Rules to Absorb and Implement
Legal Alert FINANCIAL INSTITUTIONS January 2013 Recent CFPB Mortgage Rules to Absorb and Implement January 2013 was a very busy month for the Consumer Financial Protection Bureau in promulgating rules
More informationMarch 21, Robert dev. Frierson, Secretary Board of Governors Federal Reserve System 20 th Street and Constitution Washington, DC 20551
March 21, 2016 Robert dev. Frierson, Secretary Board of Governors Federal Reserve System 20 th Street and Constitution Washington, DC 20551 Robert E. Feldman, Executive Secretary Federal Deposit Insurance
More information2013 CFPB. Mortgage Regulation U P D AT E
2013 CFPB Mortgage Regulation U P D AT E Regulations Z, B, and RESPA A two-day seminar offering an in-depth analysis of the final rules and recent revisions. September 16&17 Jackson Hilton Doubletree Hotel
More informationRe: Docket No. CFPB ; RIN 3170-AA51 CFPB proposed rule re: class action waivers and arbitral records
Via E-Mail to: FederalRegisterComments@cfpb.gov U.S. Bureau of Consumer Financial Protection 1700 G Street, NW Washington DC 20552 Attn: Monica Jackson, Office of the Executive Secretary Re: Docket No.
More informationOctober 18, Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552
October 18, 2016 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Docket No. CFPB-2016-0038 or RIN 3170-AA61 Dear Ms. Jackson:
More informationAbility-to-Repay and Qualified Mortgage Rule (ATR/QM Rule)- Effective 1/10/14
Ability-to-Repay and Qualified Mortgage Rule (ATR/QM Rule)- Effective 1/10/14 1) Dodd Frank requires that lenders make a reasonable, good-faith determination that the loan applicant has a reasonable ability
More informationTIB 2016 Annual Conference Small Creditor and Rural or Underserved Updates By: Venessa Snell
TIB 2016 Annual Conference 2016 Small Creditor and Rural or Underserved Updates By: Venessa Snell Small Creditors I. Who were you then?- 1026.35(b)(2)(iii)(B) and (C)-January 10, 2014-December 31, 2015:
More informationPUBLIC DISCLOSURE. June 4, 2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. Utah Independent Bank RSSD #
PUBLIC DISCLOSURE June 4, 2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Utah Independent RSSD # 256179 55 South State Street Salina, Utah 84654 Federal Reserve of San Francisco 101 Market Street
More informationClosing disclosure provided to the consumer three days before closing the loan
November 2, 2012 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2012-0028 Closing disclosure provided
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE February 22, 2010 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Orange County Trust Company RSSD No. 176101 212 Dolson Avenue Middletown, NY 10940 FEDERAL RESERVE BANK OF NEW YORK
More informationOctober 10, Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552
October 10, 2012 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2012-0028 Dear Ms. Jackson: I am writing
More informationCOMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE August 24, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION First State Bank of Red Bud RSSD # 356949 115 West Market Street Red Bud, Illinois 62278 Federal Reserve Bank of St.
More informationFebruary 14, Dear Ms. Naulty:
February 14, 2014 Ms. Peggy Naulty Division of Consumer and Community Affairs Board of Governors of the Federal Reserve System 20 th Street and Constitution Avenue N.W. Washington, DC 20551 Dear Ms. Naulty:
More informationPage 1 of 20 Advanced Search Search FDIC... Su Home Deposit Insurance Consumer Protection Industry Analysis Regulations & Examinations Asset Sales News & Events About FDIC Home > Regulation & Examinations
More informationImpact: Federal and State Chartered Credit Unions Relevant Department: Lending and Collections / CEO Priority Level: Medium
Comment Call (15-1) CFPB: Amendments to 2013 Mortgage Servicing Rules under Real Estate Settlement Procedures Act (Regulation X) and Truth in Lending Act (Regulation Z) Impact: Federal and State Chartered
More informationAugust 31, Robert dev. Frierson, Secretary Board of Governors Federal Reserve System 20 th Street and Constitution Washington, DC 20551
August 31, 2015 Robert dev. Frierson, Secretary Board of Governors Federal Reserve System 20 th Street and Constitution Washington, DC 20551 Robert E. Feldman, Executive Secretary Federal Deposit Insurance
More informationRequest for Information Regarding the Bureau's Adopted Regulations and New Rulemaking Authorities (Docket No. CFPB )
Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 RE: Request for Information Regarding the Bureau's Adopted Regulations and
More informationRe: Docket No. CFPB Proposal to Amend the Ability to Pay Provisions of the Credit Card Accountability Responsibility and Disclosure Act
January 7, 2013 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2012-0039 Proposal to Amend the Ability
More informationRegulation Z Michelle Nuckols, CRCM. financial services
Regulation Z Michelle Nuckols, CRCM 1 Amendments to Regulation Z The CFPB has changed the definition of small creditors, and rural and underserved areas under Regulation Z - January 1, 2016 Expands the
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE October 29, 2007 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION First Financial Bank RSSD# 48374 214 North Washington El Dorado, Arkansas 71730 Federal Reserve Bank of St. Louis P.O.
More informationRe: Request for Information on Small-Dollar Lending (Docket No. FDIC ; RIN ZA04)
January 22, 2019 Via Electronic Mail Mr. Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation 550 17 th Street NW Washington, DC 20429 Re: Request for Information on Small-Dollar
More informationRequest for Information Regarding Ability-to-Repay/Qualified Mortgage Rule Assessment
BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION [Docket No. CFPB-2017-0014] Request for Information Regarding Ability-to-Repay/Qualified Mortgage Rule Assessment AGENCY: Bureau of Consumer
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE November 26, 2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Southern Bancorp Bank RSSD# 852544 601 Main Street Arkadelphia, Arkansas 71923 Federal Reserve Bank of St. Louis P.O.
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE November 5, 2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION RSSD: 2747279 115 Third Street Marietta, Ohio 45750 Federal Reserve Bank of Cleveland P.O. Box 6387 Cleveland, OH 44101-1387
More informationMay 19, Re: Request for Information Regarding Use of Alternative Data and Modeling Techniques in the Credit Process, Docket No.
May 19, 2017 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Information Regarding Use of Alternative Data
More informationSunTrust Community Capital, LLC New Markets Tax Credit Introduction
SunTrust Community Capital, LLC New Markets Tax Credit Introduction STCC Products & Services SunTrust Community Capital (STCC) provides debt and equity capital for projects that economically benefit and
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE January 19, 2016 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION RSSD# 856748 200 South Third Street Batesville, Arkansas 72501 Federal Reserve Bank of St. Louis P.O. Box 442 St. Louis,
More informationPUBLIC DISCLOSURE. August 5, 2013 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. Pacific Enterprise Bank RSSD #
PUBLIC DISCLOSURE August 5, 2013 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Pacific Enterprise Bank RSSD # 3490871 17748 Sky Park Circle, Suite 100 Irvine, California 92614 Federal Reserve Bank
More informationThere will be subsequent presentations over the next several months which will provide:
This is an introductory presentation which will cover the basic information about the new rules including a: Practical description of the new rules and An overview of the changes There will be subsequent
More informationPPDocs System Training CFPB changes effective January 2014
PPDocs System Training CFPB changes effective January 2014 Please direct all questions to: CFPB@ppdocs.com What you should be doing today: What type of QM are you going to be doing? *Are you going to be
More informationDODD-FRANK. November 14, 2012 SPONSORED BY MORTGAGE BANKERS OF THE BLUEGRASS
DODD-FRANK November 14, 2012 SPONSORED BY MORTGAGE BANKERS OF THE BLUEGRASS Agenda Objectives Dodd Frank Overview CFPB Mission and Initiatives Pending Legislation - Qualified Mortgages (QM) - Qualified
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE March 10, 2008 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Tioga State Bank RSSD No. 910118 1 Main Street P.O. Box 386 Spencer, NY 14883 FEDERAL RESERVE BANK OF NEW YORK 33 LIBERTY
More information11 th Annual Eastern Secondary Market Conference. February 5-7, 2014 The Hyatt Regency Orlando
11 th Annual Eastern Secondary Market Conference February 5-7, 2014 The Hyatt Regency Orlando Scott D. Samlin Partner Scott Samlin is a New York partner in the firm s Financial Services & Products Group.
More informationLEGISLATIVE UPDATE CONSUMER FINANCIAL PROTECTION BUREAU MORTGAGE SERVICING RULES
LEGISLATIVE UPDATE CONSUMER FINANCIAL PROTECTION BUREAU MORTGAGE SERVICING RULES WHO: WHAT: The Consumer Financial Protection Bureau ( CFPB ) has issued new Mortgage Servicing Rules. The Mortgage Servicing
More informationRe: Docket No. CFPB Amendments to Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z)
Rod J. Alba Vice President, Mortgage Finance & Senior Regulatory Counsel 202-663-5592 ralba@aba.com October 10, 2017 Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE July 28, 2015 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Bangor Savings Bank Certificate Number: 18408 3 State Street Bangor, Maine 04401 Federal Deposit Insurance Corporation
More informationCommunity Reinvestment Act Community Development Examiner Insights
Community Reinvestment Act Community Development Examiner Insights Outlook Live Webinar February 18, 2016 Maria Villanueva Senior Examiner Federal Reserve Bank of San Francisco Matthew Holt Associate Examiner
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE January 14, 2008 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Orange County Trust Company RSSD No. 176101 212 Dolson Avenue Middletown, NY 10940 FEDERAL RESERVE BANK OF NEW YORK
More informationCFPB Notice and Request for Comment. Defining Larger Participants in Certain Consumer Financial Products and Services Markets.
CFPB Notice and Request for Comment SUMMARY: Defining Larger Participants in Certain Consumer Financial Products and Services Markets June 23, 2011 76 Fed. Reg. 38059 The Bureau of Consumer Financial Protection
More informationPUBLIC DISCLOSURE. February 7, 2011 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. Webster Bank, National Association Charter Number: 24469
O LARGE BANK Comptroller of the Currency Administrator of National Banks Washington, DC 20219 PUBLIC DISCLOSURE February 7, 2011 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Webster Bank, National
More informationComment Call (14-15) CFPB Home Mortgage Disclosure Act (HMDA)
Comment Call (14-15) CFPB Home Mortgage Disclosure Act (HMDA) Impact: Federal and State Chartered Credit Unions Relevant Department: CEO / Lending Priority Level: High Background / Credit Union Summary
More informationMay 19, 2017 VIA ELECTRONIC SUBMISSION
VIA ELECTRONIC SUBMISSION Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Dear Ms. Jackson: May 19, 2017 The undersigned, a
More informationUpon completion of this session you should: Become more familiar with the history/purpose of CRA;
CRA Basics Objectives Upon completion of this session you should: Become more familiar with the history/purpose of CRA; Become more familiar with terms and definitions under the CRA regulation; Introduce
More informationPolicy or Policies. Commercial, Lending policy. Consumer, Business Loans Originations & Servicing. Loan origination. Lending policy.
Bank: as of date TABLE OF LAWS AND REGULATIONS CONSUMER PROTECTION LAW...AND MORE (Does not include BSA/AML/OFAC/CIP) REG NAME/Recent Update - Blue generally not included in Consumer Compliance, purple
More informationCOMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE July 25, 2011 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Bank of Millbrook RSSD No. 175609 3263 Franklin Avenue Millbrook, New York 12545 FEDERAL RESERVE BANK OF NEW YORK 33 LIBERTY
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE January 26, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Amboy Bank RSSD No. 9807 3590 Highway 9 Old Bridge, NJ 08859 Federal Reserve Bank of New York 33 Liberty Street New
More informationPUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE August 25, 2008 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION RSSD: 2747279 115 Third Street Marietta, Ohio 45750 Federal Reserve Bank of Cleveland P.O. Box 6387 Cleveland, OH 44101-1387
More informationPUBLIC DISCLOSURE. October 10, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. BPD BANK RSSD No
PUBLIC DISCLOSURE October 10, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION BPD BANK RSSD No. 66015 90 BROAD STREET NEW YORK, NEW YORK 10004 Federal Reserve Bank of New York 33 Liberty Street
More informationDEPARTMENT OF HOUSING AND URBAN DEVELOPMENT. 24 CFR Part 203. [Docket No. FR 5812-N-01]
This document is scheduled to be published in the Federal Register on 11/03/2014 and available online at Billing Code: 4210-67 http://federalregister.gov/a/2014-25492, and on FDsys.gov DEPARTMENT OF HOUSING
More informationRules and Regulations
70105 Rules and Regulations Federal Register Vol. 77, No. 226 Friday, November 23, 2012 This section of the FEDERAL REGISTER contains regulatory documents having general applicability and legal effect,
More informationBringing Broadband to Maine s Rural Communities. Tuesday, October 25, 2016
Bringing Broadband to Maine s Rural Communities Tuesday, October 25, 2016 1 The Community Reinvestment Act The Community Reinvestment Act encourages depository institutions to meet the credit needs of
More informationSubmitted electronically to:
Submitted electronically to: cfpb_overdraft_forms@cfpb.gov November 3, 2017 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552
More informationPUBLIC DISCLOSURE AUGUST 16, 2010 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION AMERICAN HERITAGE BANK RSSD#
PUBLIC DISCLOSURE AUGUST 16, 2010 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION AMERICAN HERITAGE BANK RSSD# 311050 2 SOUTH MAIN SAPULPA, OKLAHOMA 74066 Federal Reserve Bank of Kansas City 1 Memorial
More informationSimplifications to the Capital Rule Pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996
December 18, 2017 Legislative and Regulatory Activities Division Office of the Comptroller of the Currency 400 7 th Street SW Suite 3E-218, Mail Stop 9W-11 Washington, DC 20219 Ms. Ann E. Misback Secretary
More informationServing and Investing in
Technical Elements (What qualifies?) Performance Context Community Development Services Community Development Investments 1 Community Development 1)Affordable housing g( (including multifamily rental housing)
More informationFinal Rule Summary. Prepared by the NASCUS State Regulatory Affairs Department October 23, 2013
Final Rule Summary Prepared by the NASCUS State Regulatory Affairs Department October 23, 2013 Interagency Rulemaking 12 CFR Part 1026; 12 CFR 722 Appraisals for Higher-Priced Mortgage Loans (Regulation
More informationR. Scott Heitkamp President and CEO of ValueBank Corpus Christi, TX
Testimony of R. Scott Heitkamp President and CEO of ValueBank Corpus Christi, TX On behalf of the Independent Community Bankers of America Before the United States Senate Committee Banking, Housing, and
More informationThe Dodd-Frank Act Small Bank Survey
The Dodd-Frank Act Small Bank Survey Agreement to Participate Does your bank agree to participate in this study? (If your bank does not agree to participate, you will be redirected away from the survey.)
More informationVIA . July 23, Ms. Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection Washington, DC 20552
VIA EMAIL Ms. Monica Jackson Office of the Executive Secretary Bureau of Consumer Financial Protection Washington, DC 20552 Re: Docket No. CFPB-20120019, RIN 3170-AA22 General Use Reloadable Prepaid Cards
More informationMortgage Servicing Rules Under the Truth in Lending Act (Regulation Z)
BILLING CODE: 4810-AM-P BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1026 [Docket No. CFPB-2017-0030] RIN 3170-AA75 Mortgage Servicing Rules Under the Truth in Lending Act (Regulation Z) AGENCY:
More informationApril 14, The Honorable Mike Crapo Chairman Committee on Banking, Housing and Urban Affairs United States Senate Washington, DC 20510
April 14, 2017 The Honorable Mike Crapo Chairman Committee on Banking, Housing and Urban Affairs United States Senate Washington, DC 20510 The Honorable Sherrod Brown Ranking Member Committee on Banking,
More information