Articles

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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Agencies Issue Clarifying Statement on Banking Hemp-Related Businesses

February 28, 2020 - 2 min read

On December 3, 2019, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN), and the Office of the Comptroller of the Currency (OCC) in consultation with the Conference of State Bank Supervisors (CSBS), issued a statement, “Providing Financial Services to Customers Engaged in…

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Michigan Banking Summary – A Tale of Two Economies?

February 26, 2020 - 5 min read

“It was the best of times. It was the worst of times.”  A Tale of Two Cities; Charles Dickens In recent months, I have opined on the sometimes-conflicting economic signals that the Market (and the Fed) have been trying to decipher in accurately forecasting what lies down the road. A decade long economic expansion that appears…

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ProBank Austin Advisor

February 24, 2020 - 1 min read

Fear has taken over financial markets as the coronavirus spreads. Current prices for financial assets always reflect expectations for future conditions. Stock prices incorporate expectations for future profits and bond prices incorporate expectations for inflation. It appears both markets will open the week with expectations of the worse for the future. In the short run,…

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ProBank Austin Advisor

February 17, 2020 - 1 min read

The data currently being released does not reflect any change to growth forecasts. The monthly data released last week confirmed no meaningful change in economic conditions as we start the new year. The U.S. economy is still growing at a 2% rate after improving by 2.3% for all of 2019. Retail sales for January were…

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