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Federal banking regulators issue statement on loan reference rates and advise prompt transition from LIBOR

CFPB Monitor

The Fed, FDIC, and OCC have issued a “ Statement on Reference Rates for Loans ” that addresses replacement rates for the London Inter-Bank Offered Rate (LIBOR). The agencies stress that banks should include fallback language that provides for the use of a “robust fallback rate” if the initial reference rate is discontinued.

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Bad Actors Emerge in PPP Lending – More Expected as Forgiveness Guidance Emerges

Abrigo

As the initial rush to secure PPP loans dies down, financial institutions now face a new set of questions: How do financial institutions handle misused, unforgiven loans and fraudulent loans? It is not too late to perform CDD and transaction monitoring of these businesses – the regulators will expect it. Lending & Credit Risk.

Lending 195
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Independent Loan Review & Credit Risk Review System Objectives

Abrigo

Independent Loan Review Systems in Banking Banking regulators have outlined expectations for effective, independent loan review and credit risk review. . The change reflects regulators’ expectations that financial institutions will develop loan review or credit review systems tailored to their specific risks and circumstances.

System 195
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Food for Thought: A Policy on Credit Exceptions

Abrigo

unsecured lending is bad rather than unsecured lending should only be extended to high pass risk rated credit). The following is an example of how I would address the structural exception of non-recourse lending. Generally speaking (subject to Regulation B), business loans should be guaranteed by the principals of the borrower.

Policies 195
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Illinois regulator issues proposed Predatory Loan Prevention Act regulations; lawsuits filed to block implementation of Act’s database reporting requirement and for declaration Act does not apply to pawn transactions

CFPB Monitor

The new law became effective immediately upon signing notwithstanding the authority it gives the Illinois Department of Financial and Professional Regulation (“IDFPR”) to adopt rules “consistent with [the] Act.”. Proposed Regulations. The IDFPR has proposed regulations to implement the Act.

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Strategies for growing commercial loans

Abrigo

You might also like this webinar on commercial lending strategy. The lack of alternative options in a rising-rate environment may be a factor when deciding to expand into commercial lending. Reference the flow chart below to ensure consistency with these decisions. . CRE Lending. Lending & Credit Risk.

Strategy 195
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How The Lending Landscape Is Quietly Changing

PYMNTS

Interest rates plummeted as the Fed held the federal funds rate at zero in the hopes of stimulating lending in an environment where credit went from dangerously free-flowing to dangerously non-existent in the span of a few months. The New Subprime Lending Path. Citigroup’s auto lending unit has been nearly entirely sold off.

Lending 137