RATA

The federal bank regulatory agencies with responsibility for Community Reinvestment Act (CRA) rulemaking today published final revisions to "Interagency Questions and Answers Regarding Community Reinvestment". The Questions and Answers document provides additional guidance to financial institutions and the public on the agencies' CRA regulations. The new and revised guidance addresses questions raised by bankers, community organizations, and others regarding the agencies' CRA regulations in the following areas: Availability and effectiveness of retail banking services. Innovative or flexible lending practices. Community development-related issues, including: (i) economic development; (ii) community development loans and activities that revitalize or stabilize underserved nonmetropolitan…

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The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation today announced the availability of the 2016 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration as community development. Distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies are designated by the agencies in accordance with their CRA regulations. The criteria for designating these areas are available on the Federal Financial Institutions Examination Council (FFIEC) website (http://www.ffiec.gov/cra). The designations continue to reflect local…

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We have started a quarterly newsletter called "Comply 365" to give you the latest news on what's happening at RATA Associates. 

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The Federal Reserve Board on Thursday announced the repeal of one regulation and a proposal to repeal a second in order to comply with statutory provisions that transferred certain consumer protection rulewriting authority to the Consumer Financial Protection Bureau (CFPB). The Board repealed its Regulation AA (Unfair or Deceptive Acts or Practices) as proposed in August 2014 and is inviting public comment on the proposed repeal of Regulation C (Home Mortgage Disclosure). The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) repealed the Board's authority to write rules that address unfair or deceptive acts or practices, which were contained in Regulation AA. Regulation AA included the Board's "credit practices rule," which prohibited banks from using certain…

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UPDATE: 02/02/2016 The official 2018 HMDA changes document was finalized in October 2015. That document had many of the ideas that were finalized but it did not contain the technical details that we need as a software provider to implement the changes. Without the "official" enumerations for all of the new fields, and more specifically on the re-used but updated fields, it is hard for us to complete specifications for our programmers.We are currently in communication with the CFPB and are trying to get clarifications on the questions we have. Once we have these answers we are planning to implement them into Comply for the 2018 reporting years and forward. The Application screens will stay the same for all years prior to 2018 then 2018 will display the new fields and the new…

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