In the News Fine on CNBC for Post-Election Coverage ICBA President and CEO Cam Fine discussed how the election could impact community banks on CNBC’s “Squawk Box” Election Night Special with Maria Bartiromo and Carl Quintanilla last night. Watch the video.
Elections Post-Election Outlook Out at Noon Look out for a special edition ICBA NewsWatch Today at noon today that will give insight on the outcomes of several key congressional races and their impact on the community banking industry.
Advocacy New Mortgage Disclosures and APR Changes Costly to Consumers and Community Banks ICBA filed two comment letters on Tuesday with the CFPB regarding the Bureau’s proposed rules on RESPA and TILA that will integrate three key mortgage disclosures. The Bureau is tasked with combining the Truth in Lending (TIL) Disclosure under Regulation Z and the Good Faith Estimate (GFE) under Regulation X, into one form now called the Loan Estimate. The CFPB is also renovating the HUD-1 and HUD 1A settlement statement, which will now be called the Closing Disclosure.
While the model forms themselves are a vast improvement over the current GFE, TIL and HUD-1 forms, the policy governing their use has broad impacts on community banks and will be costly to implement. ICBA along with the rest of the lending industry is vigorously opposing any changes to the APR calculation and its resulting impacts on HOEPA thresholds.
The ICBA does not believe the CFPB should change the finance charge calculation to include more charges which would affect the APR. The following reasons are stated in the letter: consumer testing has shown that APR disclosure is not meaningful, an artificially high APR may reduce access to credit as more loans are labeled high cost or higher-priced, requiring different APR calculations would be very burdensome for community banks, and the Dodd-Frank Act does not require a change to the APR calculation. Read the HOEPA letter.
Also, ICBA states that the Bureau must strike a balance between providing consumers with clear, timely, and reliable information regarding their mortgage loan, and not creating a regulatory framework that is inflexible, laden with rules that increase costs, extends processing times, and creates delays which result in consumer dissatisfaction. Read the RESPA/TILA letter.
Regulator SEC Extends Filing Deadline for Hurricane Sandy The Securities and Exchange Commission (SEC) announced that it is preparing relief measures that would extend filing deadlines for those affected by Hurricane Sandy and its aftermath. For the filing period of Oct. 29 to Nov. 20 for publicly traded companies, investment companies, investment advisers, other persons with filing obligations, accountants, brokerage firms and transfer agents, among others, the deadline is anticipated to be extended to Nov. 21. The SEC will also consider requests for additional relief on a case-by-case basis.
Also, see a recent article in ICBA Independent Banker on how community banks can lead their communities in preparing for potential natural disasters.
Regulator OCC Issues Warning about Fraudulent Correspondences The Office of the Comptroller of the Currency issued an alert about fraudulent correspondences that claim that funds are available from the OCC and other government entities. Correspondence may be distributed by email, fax or postal mail. The OCC states that any document claiming that the agency is involved in holding any funds for the benefit of any individual or entity is fraudulent. The OCC does not participate in the transfer of funds for, or on behalf of, individuals, business enterprises or governmental entities. See the letter. Read the notice.
Regulator Regulators Issue Technology Provider Supervision Guidelines The Federal Financial Institutions Examination Council (FFIEC), a formal interagency body empowered to prescribe uniform principles and standards, and report forms for the federal examination of financial institutions, and the regulatory agencies (FDIC, OCC and the Federal Reserve) have collectively released guidelines for the supervision of technology service providers and outsourcing technology services for institutions with total assets under $1 billion or all FDIC-supervised institutions.
The FFIEC has issued a revised information technology (IT) examination booklet, Supervision of Technology Service Providers (TSP), which addresses the supervision of third-party servicers that enter into contracts with regulated financial institutions and outlines the FFIEC's risk-based supervisory program related to the oversight of TSPs. The FFIEC has also updated the Outsourcing Technology Services Booklet, which details criteria and examination procedures a financial institution should use when outsourcing the security management function to third parties.
The Agencies (FDIC, OCC and the Federal Reserve) have also issued new Administrative Guidelines—Implementation of Interagency Programs for the Supervision of Technology Service Providers, which explain how the Agencies implement TSP supervisory programs. The Guidelines include examiner reporting templates.
Products and Services ICBA Announces BLM Technologies as New PSP ICBA announced that it has selected BLM Technologies as its Preferred Service Provider for front-line equipment sourcing and maintenance. The new agreement will provide ICBA members with a full range of cost-effective solutions for retail branch locations and home offices. From product purchase to continuing service on equipment, BLM will source such front-line equipment as check and document scanners, receipt/validation and passbook printers, coin and currency equipment, and PIN entry and signature capture devices. Certified technicians will guide end-users through the installation and troubleshooting process. BLM offers both on-site and depot repair. Read ICBA Release.