On September 27, the FHFA published Advisory Bulletin AB 2024-03 which provided guidance to FHLBanks on establishing and maintaining a member credit risk management framework. The bulletin highlighted the importance of...more
On September 27, the FHFA released its NPRM and request for comment to amend capital requirements for FHLBanks to modify limits on unsecured credit extensions. The proposal seeks to exclude interest-bearing deposit accounts...more
On August 19, the OIG for the FHFA released a report evaluating the agency’s supervision of FHLBanks following the issue of four member banks during spring 2023. The report summarized four findings: (i) the FHFA has not...more
August 13, 2024 - The Federal Reserve Bank of New York published a Liberty Street Economics blog post entitled, “When Are Central Bank Reserves Ample?” August 13, 2024 - The Federal Deposit Insurance Corporation...more
On June 20, FHFA released its request for input (RFI) on the application process for the Federal Home Loan Banks’ (FHLBanks) Affordable Housing Program (AHP). FHFA invited input on all aspects of the AHP application process,...more
Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires that six agencies — the Federal Reserve System (FRS), Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance...more
Recently, the FHFA released its annual combined operating highlights for 2023 which were prepared from the unaudited financial statements of the Federal Home Loan Bank system (FHLBank). ...more
On November 13, FHFA released an advisory bulletin on the FHLBank Framework for Pilot and Voluntary Programs. The desire for FHFA to develop innovative pilot programs is to support “affordable housing, equity advancement, and...more
On Wednesday, the Federal Housing Finance Agency (“FHFA”) released a long-awaited report on its review of the Federal Home Loan Bank (“FHLB”) System. The FHFA first announced its FHLB System at 100 initiative in August of...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
The shuttered storefronts and grounded airplanes that by now have become an all too familiar image of the COVID-19 pandemic are quickly creating a ripple effect through the U.S. economy. As unemployment rises and Americans...more
In This Issue. Federal banking regulators proposed the long-awaited “community bank leverage ratio,” which would exempt community banks with a leverage ratio of at least 9% from Basel III capital requirements; the Federal...more
FHFA Announces Increase in Maximum Conforming Loan Limits for Fannie Mae and Freddie Mac in 2017 - On November 23, 2016, the Federal Housing Finance Agency (FHFA) announced an increase in the maximum conforming loan...more
The Office of the Comptroller of the Currency, Treasury (“OCC”), Board of Governors of the Federal Reserve System (“Board”), Federal Deposit Insurance Corporation (“FDIC”), Farm Credit Administration (“FCS”), and the Federal...more
Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more
Financial regulators have proposed new rules limiting the incentive pay of employees and other service providers at financial institutions. The Dodd-Frank Act of 2010 prohibits incentive compensation that encourages...more
The National Credit Union Administration, or NCUA, became the first of six Agencies to unveil a revised rule proposal under Section 956 of the Dodd-Frank Act: prohibiting incentive-based payment arrangements that the...more
Regulatory Developments - FHFA Announces Principal Reduction Program for Struggling Underwater Homeowners - On April 14, the Federal Housing Finance Agency (FHFA) announced a new Principal Reduction Modification...more
The Federal Housing Finance Agency Releases Final Rule on Federal Home Loan Bank Membership - On January 12, 2016, the Federal Housing Finance Agency ("FHFA") issued a final rule establishing new requirements for...more
New Margin Requirements - The Board of Directors of the Federal Deposit Insurance Corporation approved a final rule to establish margin requirements for swaps that are not cleared through a clearinghouse. This action is...more
By recently releasing yet another revised representation and warranty framework, Fannie Mae and Freddie Mac continued their efforts to assuage the concerns of the lending industry that a default by a borrower poses an unfair...more
On August 27, 2015, the CFPB issued two Technical Reports: one on the National Mortgage Database (NMDB), and the other on the National Survey of Mortgage Borrowers (NSMB). The NMDB project is a joint undertaking by the FHFA...more
On August 21, 2015, Judge Alvin Thompson of the United States District Court for the District of Connecticut denied Royal Bank of Scotland Group PLC’s (“RBS”) motion for summary judgment as to claims brought by the Federal...more
On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more
On May 12, 2015, U.S. Senator Richard Shelby (R-Ala.), Chairman of the United States Senate Committee on Banking, Housing, and Urban Affairs, released the text of draft legislation intended to reform the regulatory framework...more