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CFPB Finalizes Ability to Repay/Qualified Mortgage Rules

CFPB Monitor

To qualify for the safe harbor, which is a conclusive presumption of compliance with the ability to repay rule, the APR could not exceed the APOR for a comparable transaction by (1) 1.5 or more percentage points, as applicable, the loan is eligible for a rebuttable presumption of compliance instead of a safe harbor. 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

On May 26, 2020, the OCC issued a significantly revised Sampling Methodologies booklet to be included in the Comptroller’s Handbook. On June 29, 2020, the OCC issued a new “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet to be included in the Comptroller’s Handbook.

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Effective CECL model validation: A framework

Abrigo

The OCC handbook describes a model as “a quantitative method, system, or approach that applies statistical, economic, financial, or mathematical theories, techniques, and assumptions to process input data into quantitative estimates.” Review CECL model documentation for compliance with guidelines provided by model risk management.

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How much should you segment FAS 5 (ASC 450-20) pools?

Abrigo

As stated in the Comptroller’s Handbook, “Effective management of the loan portfolio and the credit function is fundamental to a bank’s safety and soundness.” ” The ability to adequately meet ALLL, stress testing and other risk management requirements relies upon sound segmentation practices.

Handbook 150
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Is a Test Environment Necessary? 5 Reasons Why Financial Institutions Need One for Their AML & Fraud Monitoring Systems

Abrigo

Changes could stem from internal sources, like policies and procedures, new products, or product updates; or they could be external changes, like new compliance rules and regulations.

Fraud 150
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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.

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5 Common Lending Challenges and How Lending Software Can Help

Abrigo

Missing, stale or improperly executed documents can, as the OCC Comptroller’s Handbook on Loan Portfolio Management states, “exacerbate problem loans and seriously hamper work-out efforts.” Here again, an automated, centralized system that allows for the creation of ticklers and exception reporting is invaluable.

Lending 195