Page 9 - Compliance Monthly 8-12-2019

Proposed Rules

Home Mortgage Disclosure Act

On June 27, 2019, the Consumer Financial Protection Bureau (Bureau) announced that it is extending until October
15, 2019, the comment period on the Bureau’s Advance Notice of Proposed Rulemaking relating to Regulation C,

which implements the Home Mortgage Disclosure Act. The Bureau is proposing two alternatives to amend Regulation
C to increase the threshold for reporting data about closed-end mortgage loans so that institutions originating fewer

than either 50 closed-end mortgage loans, or alternatively 100 closed-end mortgage loans, in either of the two

preceding calendar years would not have to report such data as of January 1, 2020. The proposed rule would also
adjust the threshold for reporting data about open-end lines of credit by extending to January 1, 2022, the current

temporary threshold of 500 open-end lines of credit and setting the threshold at 200 open-end lines of credit upon
the expiration of the proposed extension of the temporary threshold. The Bureau is also proposing to incorporate into

Regulation C the interpretations and procedures from the interpretive and procedural rule that the Bureau issued on

August 31, 2018, and to implement further section 104(a) of the Economic Growth, Regulatory Relief, and Consumer
Protection Act

Capital Treatment of Land Development Loans

The joint agencies have invited public comment on a proposal to clarify the treatment of land development loans

under the agencies' capital rules. This proposal expands on the agencies' September 2018 proposal to revise the
definition of high volatility commercial real estate (HVCRE) as required by the Economic Growth, Regulatory Relief,

and Consumer Protection Act. The land development proposal would clarify that loans that solely finance the
development of land for residential properties would meet the revised definition of HVCRE, unless the loan qualifies
for another exemption. The land development proposal would apply to all banking organizations subject to the

agencies' capital rules. Comments will be accepted for 30 days after publication in the Federal Register (August 12,
2019).

Agencies Complete Resolution Plan Evaluations and Exten d 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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