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Last week, members of the Senate Banking Committee announced that they had reached bipartisan agreement on “legislative proposals to improve our nation’s financial regulatory framework and promote economic growth.”  Following the announcement, Committee members released a draft of a bill (S. 2155), the “Economic Growth, Regulatory Relief, and Consumer Protection Act.”  A markup of the…

The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2018 through December 31, 2018, these exemption thresholds are increased as follows:

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The federal banking agencies together with the National Credit Union Administration (the “Agencies”) issued an Interagency Advisory on the Availability of Appraisers that is intended to help address the real estate appraiser shortages being experienced by lending institutions.

Pursuant to the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), the Agencies require the…

The CFPB along with five other federal agencies have issued a final rule that establishes minimum state registration and substantive requirements for appraisal management companies (AMCs), as required by Section 1473 of the Dodd-Frank Act.  AMCs that are a subsidiary of an insured depository institution and are federally regulated (federally regulated AMCs) are subject to…

The CFPB, Fed, and OCC have adjusted the threshold for smaller loans that are exempt from the appraisal requirement for “higher priced mortgage loans.”  The appraisal requirement became effective January 18, 2014, and the exemption, which is subject to annual adjustment for inflation, currently applies to credit extensions of $25,000 or less.

Effective January…

The CFPB, Fed, FDIC, FHFA, NCUA, and OCC have finalized a supplemental rule creating several exemptions to the appraisal requirements for higher-priced mortgage loans (HPML).  Those requirements are contained in the final rule adopted jointly by the agencies in January 2013 to implement Dodd-Frank provisions mandating appraisals for HPMLs.

The final rule creates the following…

The American Bankers Association  and the Mortgage Bankers Association have sent a letter to the CFPB asking it to reconsider the applicability of the final Equal Credit Opportunity Act (ECOA) appraisal rule to business credit.  The rule applies to loan applications received on or after January 18, 2014.  It implements a Dodd-Frank amendment to the…