District Circular Letters

On April 25, 2013, the Board of Governors of the Federal Reserve System (Board) issued CA Letter 13-7 Statement on Deposit Advance Products. The letter and guidance was issued to emphasize to state member banks the significant consumer risks associated with deposit advance products in light of the Consumer Financial Protection Bureau’s (CFPB) April 24, […]

On April 19, 2013, the Consumer Financial Protection Bureau (CFPB) issued a proposal to clarify certain provisions of the Ability to Repay / Qualified Mortgage and Mortgage Servicing Rules. The proposal is in response to questions the CFPB received since the rules were issued in January 2013.

The Federal Reserve is issuing this letter to set forth guidance on sound business practices for residential mortgage servicing that Federal Reserve supervised financial institutions are expected to address in their collections, loss mitigation, and foreclosure processing functions. The guidance confirms the minimum standards that all regulated institutions are expected to adopt in prioritizing and […]

On April 5, 2013, the Federal Reserve issued SR 13-7/CA 13-4, State Member Bank Branching Considerations. This letter clarifies the Federal Reserve’s policy concerning the application process for a state member bank in less-than-satisfactory condition for the establishment of a de novo branch. The SR letter describes the circumstances under which a state member bank […]

On April 12, 2013, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to clarify and make technical amendments to the Escrow Requirements under the Truth in Lending Act (Regulation Z) (Escrow Rule). The Escrow Rule, which goes into effect on June 1, 2013, lengthens the mandatory escrow account period for HPMLs from one […]

On Monday, April 15, 2013, the Federal Reserve Board invited comment on a proposal to establish an annual assessment of bank holding companies and savings and loan holding companies with $50 billion or greater in total consolidated assets and for nonbank financial companies designated by the Financial Stability Oversight Council for supervision by the Federal […]

On April 11, 2013, the Federal Reserve issued SR 13-8/CA 13-5, “Extension of the Use of Indicative Ratings for Savings and Loan Holding Companies.” The Federal Reserve will continue to use the “RFI/C(D)” rating system (referred to as “RFI”) to assign “indicative ratings” to savings and loan holding companies (SLHCs). When the Federal Reserve assumed […]

In February 2013, the Consumer Financial Protection Bureau (CFPB) announced its plans to work with the mortgage industry and other regulators to facilitate the implementation of its mortgage rules. As part of this process, the CFPB is issuing small entity compliance guides, which are “easy-to-understand” summaries of its rules. Their first, the Small Entity Compliance […]

On March 29, 2013, the Board of Governors of the Federal Reserve System issued SR 13-6 / CA 13-3. The purpose of the letter is to highlight the supervisory practices that the Federal Reserve can employ when banking organizations and their borrowers and other customers are affected by a major disaster or emergency. In this […]

On Wednesday, April 3, 2013, the Federal Reserve Board announced approval of a final rule that establishes the requirements for determining when a company is “predominantly engaged in financial activities.” The requirements will be used by the Financial Stability Oversight Council (FSOC) when it considers the potential designation of a nonbank financial company for consolidated […]