Page 11 - Compliance Monthly 8-12-2019
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Compliance News
FAQ on TRID Integrated Disclosures
On July 31, 2019, the Bureau released frequently asked questions on providing Loan Estimates to consumers.
Payday Lending Rule Small Entity Compliance Guide
On June 28, 2019, the Bureau updated the small entity compliance guide summarizing the Payday Lending Rule’s
payment-related requirements. The guide has been updated to incorporate the changes that the Delay Final Rule
made to the 2017 Payday Lending Rule.
OCC Guidelines for Requesting a Strategic Plan
The OCC has issued Bulletin 2019-39 to inform national banks, federal savings associations, and federal branches of
foreign banking organizations (collectively, banks) about current guidelines for requesting approval to be evaluated
under the Community Reinvestment Act (CRA) using the strategic plan option or to request approval to amend an
approved CRA strategic plan. This bulletin rescinds
• OCC Bulletin 1996-11, “Community Reinvestment Act: Guidelines for Approval for a Strategic Plan &
Wholesale or Limited Purpose Institution.”
• OTS CEO Memo 268, “Strategic Plan and Wholesale/Limited Purpose Designations Under the CRA.”
These guidelines do not represent new requirements but instead summarize the OCC’s process for addressing bank
requests for approval or amendment of a CRA strategic plan, including:
• information that a bank should provide to substantiate its request.
• the email address for banks to submit requests.
• the OCC’s review and approval processes.
Agencies Complete Resolution Plan Evaluations and Extend Deadline for Certain Firms
The Federal Reserve Board and the Federal Deposit Insurance Corporation today announced several resolution plan
actions, including completing their evaluations of the 2018 resolution plans for 82 foreign banks and extending the
deadline for the next resolution plans from those firms, as well as 15 domestic banks. The extensions will give the
banks additional time to prepare their plans in light of resolution plan rule changes proposed by the agencies in
April 2019.
The agencies extended the filing deadline for the 82 foreign banks and 15 domestic banks until July 1, 2021. This
extension will mitigate uncertainty around the banks’ filing requirements while the agencies’ April proposal to
revise the resolution plan rule remains pending.
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