Written by Brandy Bruyere, Regulatory Compliance Counsel
Two Asset-size Thresholds Adjusted for Inflation.
The CFPB recently adjusted two of its asset-size exemption thresholds relating to mortgages as required by underlying statutes. The first is under Regulation C relating to the Home Mortgage Disclosure Act (HMDA). HMDA includes asset-size exemptions within its definition of the term “financial institution” so some smaller institutions receive regulatory relief from HMDA’s data reporting requirements. This asset threshold must be adjusted annually for inflation, and for 2015 the CFPB increased the threshold by $1 million. Accordingly, credit unions with assets of $44 million or less as of December 31, 2014 will be exempt from HMDA data collection requirements in 2015.
Regulation Z also includes an asset-size threshold as one of several requirements for a financial institution to be eligible for an exemption from the escrow requirements for higher-priced mortgage loans (HPMLs). The Truth in Lending Act requires the CFPB to also adjust this threshold for inflation which for 2015 is increasing from $2.028 billion to $2.060 billion in assets. It is important to note that this also impacts the qualified mortgage (QM) rules relating to small creditor portfolio and balloon payment QMs because the definition of “small creditor” cross-references this section of the HPML rule (See 12 C.F.R. 1026.43(e)(5)(i)(D)).
Cybersecurity Governance Update: New FFIEC Requirements.
It feels like there’s a new example of failed cybersecurity efforts every week. Don’t be the next. Attend this webcast to get help aligning your credit union with the FFIEC’s new cybersecurity requirements. You’ll discover the latest cyber-fraud trends, gain an understanding of the new requirements, and learn how to apply them to your risk management program.
Puppy Love. Lemmy just loves having a “human puppy” around the house, we're still working with him on his personal space issues though. As you can see, he has not quite mastered that! Also, while the holidays are a couple of weeks behind us now, I can’t help but share a photo that our son will despise when he’s a teenager—yes, that is an elf costume. A friend pointed out that he looks pretty mad about the indignity even as a baby.