Compliance Blog

Posted by Anthony Demangone

Here are a few items of interest.

The Fed.  You may have heard that the Federal Reserve has announced that it doesn't expect to complete three Regulation Z rulemaking initiatives before the CFPB assumes rulemaking authority for Regulation Z.  The rulemakings would have addressed mortgage disclosures (including HELOCs), the right of rescission, credit protection products (such as disability insurance), and reverse mortgages and modifications. You can read more about their decision via the link above.  Is the news good or bad?  Yes.  On one hand, this calms things down on the Reg Z front - at least for a little bit.  The CFPB takes hold of Reg Z in July, so these rules aren't going to be finalized before then.  But on the other hand, these issues can be picked up by the CFPB.  So the story isn't over.  How the CFPB will choose to proceed is a major unknown.  Stay tuned. 

Healthcare.  You may recall that we wrote about a certain provision of heath care reform that affected 1099s - greatly expanding their reach and increasing burdens for American businesses.  President Obama alluded to this provision in his State of the Union address, noting it was one provision that could change.  Yesterday, the U.S. Senate overwhelmingly voted to add language to an existing bill that, if enacted, would repeal that 1099 provision.  (Washingtonpost.com).  In other health care reform news, you may have seen that a judge struck down  (Washington Post) the entire health care reform law.  What does that mean? Ezra Klein provides a nice analysis.  (Washington Post.)

HMDA.  Bankersonline.com does a nice job of gathering civil money penalty information.  A number of FDIC-regulated entities have been hit with civil money penalties for HMDA violations.  A large number.   This underscores the importance of understanding HMDA, which is why I love the FFIEC's HMDA compliance guide. 

Regulation Z.  The FFIEC has announced (via the Fed) that the interagency Regulation Z examination guidelines have been updated.   This, folks, is a useful compliance resource.