On November 17, the Fed, Consumer Financial Protection Bureau, FDIC, NCUA, and OCC issued a supervisory statement to provide clarity and transparency as to the determination of the total assets of an insured depository institution or an insured credit union for the purposes of supervision and enforcement responsibilities under Sections 1025 and 1026 of the Dodd-Frank Act. The agencies have indicated that they will use the total assets reported in a depository institution’s required quarterly reports of condition, or Call Reports to determine an institution’s asset size for these purposes and that they will follow the FDIC’s deposit insurance assessment methods to determine whether an institution should be classified as a “Large Institution”. Multi-Agency Release. Supervisory Statement.
Consumer Financial Protection Bureau
CFPB Request for Comment on Definition of “Larger Participants”
On June 23, the Consumer Financial Protection Bureau released a request for comment on the statutory requirements to define who is a “larger participant” in certain consumer financial markets that will be supervised by the CFPB pursuant to Section 1024 of the Dodd-Frank Act. Comments must be submitted within 45 days after publication in the Federal Register. CFPB Release. CFPB Notice and Request for Comment.
CFPB Mortgage Loan Disclosure Initiative
On May 18, the Consumer Financial Protection Bureau announced an initiative to combine mortgage disclosures into a single form. The initiative will involve the testing of two prototype forms that will inform the CFPB’s formal rulemaking process. Treasury Release. Mortgage Disclosure Prototypes.
Fed Will Not Finalize Reg Z Rulemakings
On February 1, the Fed announced that it does not expect to finalize three pending mortgage lending rulemakings under Regulation Z, which implements the Truth in Lending Act (TILA), prior to the transfer of authority for such rulemakings to the Consumer Financial Protection Bureau in July 2011. Fed Release.