District Circular Letters

On Thursday, December 5, 2013, the Federal Reserve Board released guidance reminding financial institutions it supervises to exercise appropriate risk management and oversight when using service providers.

On November 20, 2013, the Consumer Financial Protection Bureau (CFPB) issued a final rule to integrate the mortgage disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z).

On November 18, 2013, the Federal Reserve issued two policy letters: CA 13-19 Community Bank Risk Focused Consumer Compliance Supervision Program and CA 13-20 Consumer Compliance and Community Reinvestment Act (CRA) Examination Frequency Policy. Both policies relate to the Federal Reserve’s supervision program and are effective January 1, 2014.

On November 20, 2013, the Federal Reserve Board and the Consumer Financial Protection Bureau (CFPB) announced they are increasing the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. Transactions at or below the thresholds are subject to the protections of the regulations.

On November 15, 2013, the Federal Reserve issued CA 13-18 “Final Revisions to Interagency Questions and Answers Regarding Community Reinvestment”.

On Tuesday, November 19, 2013, the federal bank regulatory agencies released an estimation tool to help community banks understand the potential effects of the recently revised regulatory capital framework on their capital ratios.

On October 15, 2013, the Consumer Financial Protection Bureau (CFPB) issued CFPB Bulletin 2013-12 to provide guidance in implementing certain provisions of the 2013 Real Estate Settlement Procedures Act (RESPA) and Truth in Lending Act (TILA) Servicing Final Rules. The CFPB issued the 2013 RESPA and TILA Final Rules in January 2013, and they take effect on January 10, 2014.

On November 8, 2013, the Consumer Financial Protection Bureau (CFPB) issued CFPB Bulletin 2013-13 to provide guidance to lenders regarding the homeownership counseling list requirement finalized in the High-Cost Mortgage and Homeownership Counseling Amendments to the Truth in Lending Act (Regulation Z) and Homeownership Counseling Amendments to the Real Estate Settlement Procedures Act (RESPA Homeownership Counseling Amendments) Final Rule, collectively referred to as the 2013 HOEPA Final Rule. The 2013 HOEPA Final Rule, originally issued in January 2013, is effective January 10, 2014.

On October 30, 2013, the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council approved the attached interagency examination procedures for the Garnishment of Accounts Containing Federal Benefit Payments Rule (Garnishment Rule).

On October 30, 2013, the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council approved the attached interagency examination procedures for Regulation E – Electronic Fund Transfers.