Articles

ProBank Austin Advisor

March 30, 2020 - 1 min read

Economic data is of little value in making longer-term forecasts. It is too early in the health crisis to be able to forecast the nature of economic conditions when this passes. There are forecasts of a V-shaped business cycle where growth surges in either the third quarter or fourth. There are forecasts of a U-shaped…

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Voluntary Credit Union Diversity Self-Assessment

March 24, 2020 - 1 min read

In a letter to Credit Unions, 19-CU- 03, NCUA chairman, Rodney E. Hood, reemphasizes the value of the voluntary Credit Union Diversity Self-Assessment Tool. The tool is not part of the NCUA’s or state regulators’ examination process and has no impact on a credit union’s CAMEL rating. Rather, the tool serves as a guide to improve…

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ProBank Austin Advisor

March 23, 2020 - 1 min read

New proposals are being made each day which makes forecasting impossible. Economic forecasting is worthless at this point. While first quarter Real GDP may come in at better than expected levels, second quarter data is unknown. There is little reason to guess at the economic impact of current conditions. We have seen some forecasts of…

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Michigan Banking Summary – EPS Estimates Take a Backseat to CDC Forecasts

March 19, 2020 - 8 min read

Roughly a month ago, no one thought we’d be dusting-off “pandemic-oriented” contingency plans, but here we are. Seemingly weeks, or months, if not years of activity on multiple fronts (economic and social), feels like it has been condensed into a few days. The daily volatility in the markets is succinctly summarized in the chart below:…

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CFPB Requests for Information Regarding TRID

March 17, 2020 - 2 min read

The Bureau of Consumer Financial Protection (Bureau) is conducting an assessment of the Integrated Mortgage Disclosures under the Real Estate Settlement Procedures Act (Regulation X) and the Truth-In-Lending Act (Regulation Z) Rule and certain amendments. The Bureau is requesting public comment on its plans for assessing this rule, as well as certain recommendations and information…

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ProBank Austin Advisor

March 16, 2020 - 1 min read

The Fed has moved aggressively to address the possible impact of the health crisis. The Fed dropped managed rates by 100 bp on Sunday night. They have now moved rates down by 150 bp, all between FOMC meetings. They also announced a new QE program of buying $700 billion of bonds and dropped rates at…

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A Pandemic Planning Suggestion

March 16, 2020 - 1 min read

  This will be my shortest blog post ever.  But, one that may become very important. Do you have a clear understanding of your critical vendors’ (including core processing) escalation policies? If a situation arose and your institution requires assistance or other form of consideration from your vendors, do you know how to escalate that if your…

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Servicemember Civil Relief Act’s 6% Interest Rule

March 10, 2020 - 2 min read

Institutions are advised to be reminded of a relatively recent revision to the Servicemember Civil Relief Act (SCRA) regarding the 6% rule. ProBank consultants have been finding numerous institutions that are not aware of this change. On August 13, 2018, the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (HR 5515; Pub Law…

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ProBank Austin Advisor

March 9, 2020 - 1 min read

Economic data from the first two months of the year means nothing in a period of panic. The worst conditions one can imagine are being priced in financial markets. This is being caused by the fear of the unknowns, with respect to the coronavirus being the major unknown, but there are others. The political outlook…

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CFPB Releases Construction Loan Guides

March 4, 2020 - 1 min read

On Wednesday, December 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guidance documents related to disclosing construction and construction-permanent loans under the TILA-RESPA Integrated Disclosure (TRID) Rule using the Loan Estimate and Closing Disclosure forms. One guide addresses a combined, one-transaction disclosure construction-to-permanent loan. The other provides guidance on disclosing a construction-to-permanent loan…

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ProBank Austin Advisor

March 2, 2020 - 1 min read

Throw out fundamentals as investors have headed for the exits. Panic is ugly to watch. Investors headed for the exit on Wall Street last week and the exit was not wide enough to allow an orderly evacuation. Stock prices were hammered, and capital flowed into the U.S. treasury market to be parked in a safe…

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