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 treatments, ended up being updated to permit filing of notices and applications utilizing electronic news, such as for instance 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 Division’s methodology for determining the cost.

Nutter Notes : In past rounds of its regulatory review initiative, the Division has granted revisions to

its regulatory bulletins pertaining to lending that is fair, information technology danger management, restrictive rent covenants, CRA reviews, and marketing recommendations for CDs and money market records. The Division revised Regulatory Bulletin 1.3-103, Consumer Protection and Fair Lending exams, to simplify the Division’s authority to enforce state and regulations that are federal. Regulatory Bulletin 2.3-102, CRA reviews Policy, ended up being revised to make clear the applicability regarding the Division’s guidance to institutions that are large. Regulatory Bulletin 2.3-103, Alternative CRA Examination treatments, happens to be renumbered as Regulatory Bulletin 1.3-105 and updated to include Mortgage Lender Community Investment exams which are carried out because of the Division at particular mortgage brokers. Regulatory Bulletin 2.2-102, Management Ideas Systems https://online-loan.org/title-loans-fl/englewood/ exams, happens to be repealed in its entirety. Particular guidance included in the previous Regulatory Bulletin 2.2-102 handling the necessity for I . t providers to give a Letter of Assurance acknowledging that their services is supposed to be at the mercy of regulation and assessment because of the Division towards the exact same level as 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 instructions, is repealed with its entirety.

3. FDIC and OCC Propose Assistance With Pay Day Loans

The FDIC and OCC have actually released proposed guidance to depository organizations offering or may start thinking about deposit that is offering credit services and products, commonly named payday advances. The proposals released concurrently on April 15 would caution banking institutions about many different safety and soundness, compliance and customer security risks posed by deposit advance loans. The guidance that is proposed the axioms that the FDIC and OCC each expect depository institutions to adhere to associated with deposit advance products so that you can handle dangers linked to payday lending, including appropriate, reputational, customer security, conformity and credit dangers. The proposition additionally talks about supervisory objectives for making use of deposit advance services and products, including underwriting and credit management policies and methods. The proposition describes deposit advance services and products as a form of small-dollar, short-term credit product wanted to consumers by having a deposit account, reloadable prepaid credit card or comparable deposit-related automobile at a bank whereby the lender offers a credit feature which allows the customer to simply simply simply take away that loan prior to the consumer’s next direct deposit on the basis of the consumer’s reputation for recurring deposits. The proposed guidance encourages banking institutions to carry on to provide these items, in line with security and soundness along with other supervisory factors. The proposition supplements current FDIC and OCC guidance on pay day loans and lending that is subprime. Responses in the proposed guidance are due by might 30, 2013.