July 09, 2014
Masthead 2

 
Contents:
Small Creditor Exemption Urged
Host-State Loan-to-Deposit Ratios
Operation Choke Point
Credit Plentiful in Rural America


Crowe-Horwath



A Bank's Private Cloud




6 Bridges




Harland Clarke


Travelers


 
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Real Community Bank
Small Creditor Exemption Urged 
ICBA sent a letter to the CFPB strongly urging the bureau to broaden the "small creditor" exception for the qualified mortgage/ability-to-repay mortgage rules and the escrow requirements for higher-priced mortgages.

The rules state that to qualify for the exception, a small creditor and its affiliates must have originated 500 or fewer covered transactions secured by a first lien in the preceding calendar year and had total assets of less than $2 billion at the end of the preceding calendar year.

ICBA wrote that it agrees with the idea behind the small-creditor exception, but that the CFPB should broaden the exception to include all community bank mortgage loans held in portfolio for the life of the loan because the bank will automatically have a vested interest in the loans' performance.

If the CFPB does not pursue this recommendation, it should, at the very minimum, increase the loan-volume threshold to at least 2,000 first-lien mortgage loans or disregard loans sold into the secondary market when applying the annual loan-threshold number, ICBA said.

If the financial institution is willing to take 100 percent of the credit risk by holding the mortgage loan in portfolio, then all of these loans should have QM safe harbor status and be exempt from escrow requirements, ICBA wrote.

Read the ICBA Letter.

Host-State Loan-to-Deposit Ratios  

The Board of Governors of the Federal Reserve System, the FDIC, and the OCC issued the host state loan-to- Regulator Collage deposit ratios that they will use to determine compliance with section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994. These ratios update data released on July 1, 2013.

 

In general, section 109 prohibits a bank from establishing or acquiring a branch or branches outside of its home state primarily for the purpose of deposit production. Section 109 also prohibits branches of banks controlled by out-of-state bank holding companies from operating primarily for the purpose of deposit production.

 

Section 109 provides a process to test compliance with the statutory requirements. To view the steps and to see the Host-State Loan-to-Deposit Ratios, click the attachment below.   

Operation Choke Point

U.S. House Representative Blaine Luetkemeyer (R-MO) introduced a bill last week that seeks to put an end to "Operation Choke Point," an anti-fraud initiative led by the Department of Justice (DOJ).   

Critics of the DOJ initiative say pressure on banks has led to legitimate businesses being cut off by banks, and ultimately losing access to the payment system.

 

Rep. Luetkemeyer's bill, called the End Operation Choke Point Act, aims to end the DOJ's initiative by providing a safe harbor for banks.  Under the End Operation Choke Point Act, banks and credit unions would have legal protection against regulatory pressures if their merchant customers meet one of three criteria.  These criteria are: having a license to offer the product or services being sold; being registered as a money services business; or providing a legal opinion that demonstrates the legality of its business operations.   

Credit Plentiful in Rural America 
Community bank credit for agricultural producers is plentiful and available at historically low rates, ICBA Senior Vice President of Agriculture and Rural Policy Mark Scanlan told RFD-TV. In an interview with the news network focused on rural America, Scanlan cited recent ICBA congressional testimony and an ICBA survey on farm lending. Watch the Clip.

Thursday, July 10, 2014  

 

Q2 2014 Regulatory Compliance Briefing

  

This is a complimentary webinar offered by ACB's Preferred Service Provider Continuity Control 

 

Monday, July 14, 2014

Wednesday, July 23, 2014

Thursday, July 31, 2014