RMA's Regulatory Update Podcast - Three Items


On April 12, 2017 the Office of the Comptroller of the Currency issued the “Retail Lending” booklet of the Comptroller’s Handbook. This new booklet discusses the risks associated with retail lending and provides a framework for evaluating retail credit risk management activities. The booklet supplements the core assessment sections of the “Large Bank Supervision,” “Community Bank Supervision,” and “Federal Branches and Agency Supervision” booklets of the Comptroller’s Handbook.

The OCC directs its examiners to refer to this new booklet when specific retail lending products, services, activities or risks warrant review beyond the core assessment because they have a material impact on the risk profile and financial condition of national banks and federal savings associations. The booklet describes:

  • Characteristics of an effective retail credit risk management framework.
  • Criteria examiners should consider when evaluating retail credit originations, account management, collections, and portfolio management activities and processes.
  • Objectives of control functions commonly used in a retail lending business to measure performance, make decisions about risk, and assess the effectiveness of processes and personnel.


The Federal Deposit Insurance Corporation (FDIC) has published a new guide to help community bankers learn more about the programs and products offered by the Federal Home Loan Banks (FHLBanks) to facilitate mortgage lending. The Affordable Mortgage Lending Guide, Part III: Federal Home Loan Banks describes many of the products and services offered by the FHLBanks, including advances, the Affordable Housing Program, the Community Investment Program, the Mortgage Purchase Program, and the Mortgage Partnership Finance program. The guide also describes FHLBanks products that support single-family home purchases, such as down payment and closing cost assistance, and alternatives for selling mortgages on the secondary market.

The Affordable Mortgage Lending Guide, Part I: Federal Agencies and Government-Sponsored Enterprises was released in September 2016 and Part II: State Housing Finance Agencies was released in November 2016. Parts I, II, and III of the Affordable Mortgage Lending Guide can be found on the FDIC’s Web site.


On April 13, 2017 the Consumer Financial Protection Bureau issued a proposal intended to facilitate compliance with the 2015 updates to the Home Mortgage Disclosure Act (HMDA) rule. The proposed changes seek to clarify the information institutions are required to collect and report regarding mortgage lending.

The Dodd-Frank Act required the CFPB to update the HMDA regulation to improve the quality and type of data reported by financial institutions. The update was finalized in 2015 and most of the update requirements take effect in January 2018. The CFPB notes that institutions are working to achieve compliance. Through public outreach and engagement, the CFPB has identified opportunities to clarify parts of the 2015 rule, which the Bureau believes will help compliance efforts.

This proposal clarifies certain key terms, such as temporary financing and automated underwriting system. The proposal would also establish transition rules for reporting certain loans purchased by financial institutions. Another proposed change would facilitate reporting of the census tract of a property, using a new geocoding tool the CFPB plans to provide online.

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