On May 12, 2020, the Federal Deposit Insurance Corporation (FDIC) approved a proposed rule designed to help alleviate the deposit insurance assessment effects of participating in certain programs established by the U.S. Small Business Administration and the Board of Governors of the Federal Reserve System....
On April 9, 2020, the federal bank regulatory agencies declared an interim final rule related to the Small Business Administration’s Paycheck Protection Program (PPP). The Coronavirus Aid, Relief, and Economic Security (CARES) Act established the PPP to provide loans to small businesses to keep workers...
In the summer of 2017, the Federal Deposit Insurance Corporation (FDIC) provided guidance on managing liquidity risks in the 21st century. In volume 14, issue 1 of the FDIC’s ‘Supervisory Insights,’ regulators outline their observations regarding liquidity threats, the risks these threats pose to financial...
During these unprecedented times, banks may be asked by customers about loan payment deferrals. While this can be a straightforward process for consumer non-real estate loans and business loans, residential real estate loans can be a bit more challenging. You will need to address Truth...
The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) recently released a joint statement on heightened cybersecurity risks. While many financial institutions are addressing the identified threats, there may be recommendations in the guidance that are new to your...
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) updated its Currency Transaction Report (CTR) Electronic Filing Requirements document in October 2019 and again modified these details in November 2019. A quick summary of the latest changes and text from applicable sections of the...
The Department of the Treasury Financial Crimes Enforcement Network (FinCEN) requires financial institutions to file currency transaction reports (CTRs) for certain cash transactions, and many transactions are performed by persons or legal entities doing business under a different name or names. FinCEN has provided clarification...
Since the inception of TILA-RESPA Integrated Disclosure (TRID) rules, many questions exist about how these regulations apply to construction loans. The Consumer Financial Protection Bureau recently released two companion guides focused on disclosing these types of loans under the TRID rules. The first guide (https://files.consumerfinance.gov/f/documents/cfpb_trid-combined-construction-loan-guide.pdf)...
It is important to review your real estate valuation program, as it is fundamental to the value of your loan portfolios. Remaining apprised of real estate value fluctuations and obtaining periodic appraisals according to the rules can keep you ahead of the game. What are the...
Your borrowers are your stock in trade; however, shopping around is a way of life for many Americans. Even a borrower who is content with your services could seek a better lending deal at any time. To prevent this, you need to develop your borrower...