Compliance Update - Dec. 22, 2023
Associations Seek Information on FHFA Credit Score Changes
In a letter to the Federal Housing Finance Agency (FHFA) Director Sandra Thompson, a group of financial and housing industry associations urged the agency to disclose the analyses supporting its final rule related to credit score modernization. The rule involves replacing the FICO credit score model used by Fannie Mae and Freddie Mac with the FICO 10T and VantageScore 4.0 credit score models. The letter also emphasized the need for transparency regarding the decision to shift from requiring three credit reports to two for single-family loans.
Read the Letter
FinCEN Begins Beneficial Ownership Information Data Collection
The Financial Crimes Enforcement Network (FinCEN) has begun accepting beneficial ownership information reports as mandated by the Corporate Transparency Act. A final rule issued last month implements a phased approach to access, starting with a pilot program for federal agencies in 2024, with financial institutions gaining direct access in the final phase. The final rule also permits banks to use the information for compliance purposes under the Bank Secrecy Act.
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Read the Final Rule
CRA Small Bank Definitions Updated
The Federal Reserve and Federal Deposit Insurance Corporation (FDIC) announced the asset-size threshold under the Community Reinvestment Act (CRA). A small bank is defined as one with assets less than $1.564 billion as of Dec. 31 in either of the preceding two calendar years. An intermediate small bank has assets of at least $391 million as of Dec. 31 in both of the preceding two calendar years and less than $1.564 billion as of Dec. 31 in either of the prior two calendar years. These updated thresholds became effective on Jan. 1, 2024.
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Biden Vetoes Resolution to Overturn Section 1071 Rule
President Biden vetoed a Senate joint resolution to overturn the Consumer Financial Protection Bureau's (CFPB) final rule implementing Section 1071 of the Dodd-Frank Act, which requires the collection and reporting of credit application data for small businesses.
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