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 Procedures, ended up being updated allowing filing of notices and applications making use of media that are electronic such as for example through FDICconnect. The Division additionally 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 costs, to add the DivisionвЂ™s methodology for determining the cost.
Nutter Notes : In past rounds of its regulatory review effort, the Division has given revisions to
its regulatory bulletins pertaining to reasonable lending exams, I . t danger administration, restrictive rent covenants, CRA ranks, and marketing directions for CDs and cash market records. The Division revised Regulatory Bulletin 1.3-103, customer Protection and Fair Lending exams, to simplify the DivisionвЂ™s authority to enforce state and federal laws. Regulatory Bulletin 2.3-102, CRA reviews Policy, had been revised to simplify the applicability associated with the DivisionвЂ™s guidance to big organizations. Regulatory Bulletin 2.3-103, Alternative CRA Examination Procedures, was renumbered as Regulatory Bulletin 1.3-105 and updated to add Mortgage Lender Community Investment exams which can be carried out by the Division at specific lenders. Regulatory Bulletin 2.2-102, Management Suggestions Systems exams, is repealed in its entirety. Particular guidance included in the previous Regulatory Bulletin 2.2-102 handling the necessity for information technology providers to supply a Letter of Assurance acknowledging that their services will undoubtedly be susceptible to legislation and assessment because of the Division to your extent that is same in the event that solutions 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 continues to be 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Regulatory Bulletin 2.3-105, Certificate of Deposit and Money marketplace Account Advertising recommendations, is repealed with its entirety.
3. FDIC and OCC Propose Assistance With Payday Advances
The FDIC and OCC have actually granted proposed guidance to depository organizations offering or may give consideration to offering deposit advance 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, conformity and customer protection risks posed by deposit advance loans. The guidance that is proposed the concepts that the FDIC and OCC each expect depository organizations to adhere to regarding the deposit advance services and products to be able to handle dangers associated with payday lending, including appropriate, reputational, customer security, conformity and credit dangers. The proposition also talks about supervisory objectives for the usage deposit advance items, including underwriting and credit administration policies and techniques. The proposition describes deposit advance services and products as a form of small-dollar, short-term credit item provided to consumers by having a deposit account, reloadable prepaid credit card or comparable deposit-related automobile at a bank whereby the financial institution provides a credit function which allows the customer to just simply take a loan out in advance of the consumerвЂ™s next direct deposit on the basis of the consumerвЂ™s history of recurring deposits. The proposed guidance encourages banking institutions to carry on to supply the products, in line with safety and soundness as well https://online-loan.org/title-loans-co/boulder/ as other supervisory considerations. The proposition supplements current FDIC and OCC guidance on payday advances and subprime financing. Commentary regarding the proposed guidance are due by might 30, 2013.