All banks and credit unions must adhere to other existing guidance applicable to investment policy requirements though the Division cautions that, despite the repeal of this bulletin. Regulatory Bulletin 2.1-104, Branch workplace Notice and Application treatments, ended up being updated to permit filing of notices and applications utilizing media that are electronic such as for instance through FDICconnect. The Division also combined its guidance for Fair Lending and CRA evaluation requirements into one bulletin, Regulatory Bulletin 1.3-106, Community Reinvestment and Fair Lending Policy, and updated Regulatory Bulleting 2.3-106, Deposit Return Item charges, to add the Division’s methodology for determining the cost.
Nutter Notes : In past rounds of the regulatory review initiative, the Division has given revisions to
its regulatory bulletins pertaining to lending that is fair, I . t danger administration, restrictive lease covenants, CRA reviews, and marketing tips for CDs and cash market accounts. The Division revised Regulatory Bulletin 1.3-103, Consumer Protection and Fair Lending exams, to simplify the Division’s authority to enforce state and regulations that are federal. Regulatory Bulletin 2.3-102, CRA reviews Policy, had been revised to simplify the applicability associated with Division’s guidance to institutions that are large. Regulatory Bulletin 2.3-103, Alternative CRA Examination treatments, happens to be renumbered as Regulatory Bulletin 1.3-105 and updated to include Mortgage Lender Community Investment examinations being carried out by the Division at particular mortgage brokers. Regulatory Bulletin 2.2-102, Management Information Systems exams, happens to be repealed in its entirety. Particular guidance within the previous Regulatory Bulletin 2.2-102 handling the necessity for I . t providers to produce a Letter of Assurance acknowledging that their solutions is likely to be at the mercy of legislation and assessment because of the Division towards the same degree as in the event that services had been being done because of the entity it self by itself premises happens to be updated and integrated into Regulatory Bulletin 1.1-101, Examination Policies, which stays under review. Regulatory Bulletin 2.2-103, Exclusive Leases and Other Restrictive Agreements, happens to be updated to broaden the exemptions from the limitations.
Regulatory Bulletin 2.3-105, Certificate of Deposit and Money marketplace Account Advertising instructions, is repealed with its entirety.
3. FDIC and OCC Propose Help With Pay Day Loans
The FDIC and OCC have actually given proposed guidance to depository organizations that provide or may start thinking about deposit that is offering credit services and products, commonly called payday advances. The proposals released concurrently on April 15 would caution banking institutions about a number of security and soundness, compliance and customer security risks posed by deposit advance loans. The proposed virginia payday loans near me guidance defines the concepts that the FDIC and OCC each expect depository organizations to check out associated with deposit advance services and products so that you can handle dangers linked to payday lending, including appropriate, reputational, customer security, conformity and credit dangers. The proposition additionally covers supervisory objectives for the employment of deposit advance services and products, including underwriting and credit management policies and techniques. The proposition defines deposit advance items as a form of small-dollar, short-term credit product provided to consumers having a deposit account, reloadable prepaid credit card or comparable deposit-related car at a bank whereby the lender supplies a credit function that enables the customer to simply simply take a loan out prior to the consumer’s next direct deposit in line with the consumer’s reputation for recurring deposits. The proposed guidance encourages banking institutions to carry on to supply these items, in line with security and soundness along with other supervisory factors. The proposition supplements current FDIC and OCC guidance on pay day loans and lending that is subprime. Remarks regarding the guidance that is proposed due by might 30, 2013.
