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CFPB Finalizes Ability to Repay/Qualified Mortgage Rules

CFPB Monitor

The CFPB recently issued a final rule amending Regulation Z ability to repay rule/qualified mortgage (QM) requirements to replace the strict 43% debt-to-income (DTI) ratio basis for the general QM with an annual percentage rate (APR) limit, while still requiring the consideration of the DTI ratio or residual income. 1 and II.A.4-5 1 and II.A.4-5

Handbook 148
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Federal and State Banking Regulators Issue New Examination Procedures on Sampling Methodologies, UDAP/UDAAP, and CARES Act

CFPB Monitor

Recently, the federal banking regulators issued four new sets of examination procedures. On May 26, 2020, the OCC issued a significantly revised Sampling Methodologies booklet to be included in the Comptroller’s Handbook.

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How to Measure Interest Rate Risk Effectively in Banks & Credit Unions

Abrigo

Takeaway 1 Regulators stress sound risk management practices that include the ability to identify and measure interest rate risk (IRR). Regulators have repeatedly stressed the importance of sound risk management practices that include the ability to identify and measure interest rate risk. EVE Analysis.

How To 195
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Effective CECL model validation: A framework

Abrigo

Takeaway 2 Regulators say management should periodically validate the loss estimation process for the allowance for credit losses (ACL) and any changes to it. Regulators have noted such risks can involve financial losses, poor business and strategic decision-making, or damage to a bank’s reputation.

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Important Considerations When Growing the CRE Portfolio

Abrigo

The OCC Comptroller’s Handbook on CRE lending is careful to point out that CRE lending brings a unique take on other common lending risks, such as credit, interest rate, liquidity, operational, compliance, strategic and reputational risks. For many, commercial real estate lending may be the ticket.

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How to stress test your ag portfolio

Abrigo

According to the Comptroller’s Handbook on Agricultural Lending , the repayment of agriculture loans often depends on successful planting and harvesting of crops, or raising and feeding of livestock, and ultimately marketing the harvested item(s). Without diversification, risks will be expounded.

How To 150
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CFPB proposes Regulation Z changes to address discontinuation of LIBOR index; Ballard Spahr to hold July 14 webinar

CFPB Monitor

The CFPB has proposed amendments to Regulation Z to address the discontinuation of the London Inter-Bank Offered Rate (LIBOR) that is currently used by many creditors as the index for calculating the interest rate on credit cards and other variable-rate consumer credit products. ” Click here to register. Change in index.