Compliance News

The latest compliance news items. Past months’ news items are found under the specific Compliance Topic page related to the news item.

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May 2018 | June 2018

June News

  • ABA, Trade Groups Urge Fixes to Bureau Remittance Rule (6/20/18)
    As part of the Bureau’s ongoing feedback initiative, the American Bankers Association and its transaction banking subsidiary BAFT, joined by the Clearing House and the Consumer Bankers Association, urged the Bureau to make several much-needed rule changes to its remittance rule. Specifically, the groups urged the Bureau to exclude transfers that are outside the commonly understood scope of remittances; preserve depository institutions' ability to estimate fees and exchange rates, rather than providing third parties' actual rates and fees; provide more flexibility and reducing redundancy in disclosures; and modify error resolution provisions. Contact Rob Rowe with questions.
  • ABA Asks Bureau to Review New and Adopted Rules (6/18/18)
    The Bureau of Consumer Financial Protection should consider whether the rules it has written since opening its doors are "consistent with the law, clear, and whether they promote the financial interests of consumers in a strong, vibrant, and innovative market that offers the variety of financial products and services that consumers want and value," the American Bankers Association said in a comment letter to the Bureau today. The letter—the eighth of 12 that the association will submit in response to the Bureau's ongoing feedback initiative—identified the banking industry's key priorities for reform of the rules governing remittance transfers, mortgage origination and servicing, and prepaid cards. For more information, contact ABA's Virginia O'Neill.
  • Trump to Nominate Kathy Kraninger to Lead Bureau (6/18/18)
    President Trump will nominate Kathy Kraninger, a top aide at the Office of Management and Budget, as director of the Bureau of Consumer Financial Protection, the White House confirmed Saturday. Kraninger is an associate director at OMB responsible for financial regulatory agency budgets, and previously served as Senate staff on Capitol Hill and at the Department of Homeland Security. Upon confirmation, Kraninger would replace CFPB Acting Director Mick Mulvaney, who is also the confirmed director of OMB. Kraninger’s nomination comes at a key moment for the CFPB; under the Federal Vacancies Reform Act, Mulvaney’s stint as acting director would have expired this month, but when a permanent replacement is nominated, the clock resets, allowing Mulvaney to remain as acting director until Kraninger is confirmed.
  • OCC Bulletin Clarifies CRA Supervisory Policies and Processes (6/15/18)
    While its efforts to modernize Community Reinvestment Act regulations proceed along a separate track, the OCC on Friday issued a bulletin to clarify current OCC policies and processes for assessing banks' CRA performance. These policy clarifications, which are effective immediately, address: implementation of full-scope and limited-scope reviews; consideration of activities that promote economic development; use of demographic, aggregate, and market share data; evaluation of the borrower distribution of loans outside bank assessment areas; evaluation frequency and timing; the CRA performance evaluation period; and, evaluation of home mortgage loans.
  • Agencies Rescind Policy Statement on Interagency Notification of Formal Enforcement Actions (6/13/18)
    The Federal Financial Institutions Examination Council rescinded its revised policy statement on "Interagency Coordination of Formal Corrective Action by the Federal Bank Regulatory Agencies," dated Feb. 20, 1997. This guidance applies to all OCC-supervised institutions.
  • ABA Foundation Releases Free Guide to Partnerships That Protect Senior Customers (6/11/18)
    To mark World Elder Abuse Awareness Day on Friday, the ABA Foundation this week is releasing a free new guide to help bankers combat financial exploitation of seniors. The new guide provides an overview of the state of financial exploitation; addresses top scams currently in play; examines what banks can do, including how to report suspected fraud; and outlines the distinct roles of law enforcement agencies and adult protective services and how to partner with them. It also includes several sample resources, including introduction letters to law enforcement, APS, senior-focused nonprofits and senior living facilities. Learn more at aba.com/seniors.
  • Mulvaney: Bureau Working to Create 'Community Networks' to Counter Elder Abuse (6/11/18)
    The Bureau of Consumer Financial Protection Acting Director Mick Mulvaney said at a town hall event in Topeka, Kan., on Friday that the Bureau is working to form "community networks" of local law enforcement agencies and state financial regulators that can work together with the Bureau to counter elder financial abuse and "find where the problems are." "We are good at collecting data, but you're on the ground," Mulvaney said, calling on state attorneys general to play an active role in building these community networks over the next several months. "You are where the rubber meets the road. And you have a much better chance of focusing on solving that problem." He added that "it is our goal to have this in place by the end of the calendar year."
  • ABA Urges Simpler, More Transparent Rulemaking Process at Bureau (6/8/18)
    The Bureau of Consumer Financial Protection should target its rulemaking process more precisely on the consumer harms it seeks to address and do so in a clear, simple and transparent manner, ABA said in a comment letter to the Bureau. "The Bureau's rulemaking record to date is best characterized as a series of ambitious undertakings riddled with unintended — but often foreseeable — consequences," ABA said. To mitigate these problems, ABA made several specific suggestions, including: simplifying the overall rulemaking process to avoid frequent and costly follow-up rules; better incorporating feedback from small business review panels; and creating a chief economist's office to conduct cost-benefit analysis, among others. Contact Shaun Kern with questions.
  • ABA Supports Creation of Database of Reassigned Phone Numbers (6/8/18)
    In a comment letter to the Federal Communications Commission, ABA urged the FCC to continue developing a centrally administered database of phone numbers that have been relinquished by one individual and reassigned to another. ABA also called on the FCC to provide a safe harbor for banks and other callers that use the database and to grant the joint petition submitted by ABA, the U.S. Chamber of Commerce and several other industry groups in early May asking for a new interpretation of the definition of an "automatic telephone dialing system," commonly known as an "autodialer." For more information, contact ABA's Jonathan Thessin.
  • Bureau to Retool Advisory Councils; Dismisses Current Members (6/7/18)
    The changes come after receiving requested feedback from ABA and others on its external affairs process. As part of this process, the Bureau dismissed all members of the Bureau's advisory boards and councils, including its community bank and credit union councils and the Consumer Advisory Board, which is mandated by the Dodd-Frank Act to meet twice a year. The Bureau will select new members through the current application cycle, for which applications were due in April. All three bodies will be smaller.
  • ABA Staff Analysis: FFIEC Customer Due Diligence and Beneficial Ownership Exam Procedures (6/6/18)
    ABA released a summary and guidance on the FFIEC's Customer Due Diligence (CDD) and Beneficial Ownership Exam Procedures issued on May 11. The exam procedures are in two parts, reflecting the two parts of the regulation. ABA members must login to view the Staff Analysis. For more information, contact ABA's Rob Rowe.
  • Treasury to Update OFAC Website on June 7 (6/5/18)
    The Treasury Department will be updating the HTTPS certificate it uses for the Treasury.gov domain on June 7. Users may have to reinstall the root certificate for the site if they experience connection problems.
  • OIG Releases Semiannual Report to Congress (6/5/18)
    The Office of Inspector General (OIG) released its Semiannual Report to Congress, reporting on the Bureau's and the Federal Reserve's programs and operations from October 2017 through March 2018. The OIG found that since its last report in October, the Bureau has taken steps to mature its information security program to ensure that it is consistent with FISMA requirements. The OIG also reports that the Bureau has offboarding controls related to conflicts of interest for executive employees' postemployment restrictions; however, the Bureau has opportunities to strengthen controls related to other components of the employee offboarding process.
  • ABA Urges Bureau to Cease Public Complaint Database (6/4/18)
    In a comment letter to the Bureau — the sixth of 12 the association will submit as part of the Bureau’s ongoing feedback initiative — ABA urged the Bureau to cease the publication of individual consumer complaints, including complaint narratives. Congress in the Dodd-Frank Act did not authorize the Bureau to publish individual complaints, but the Bureau — under orders from former Director Richard Cordray — established a public database of complaints. ABA urged the Bureau to focus on its statutory mandate: overseeing the individual responses to consumer complaints, analyzing complaint data for supervisory oversight and policy-making purposes, and providing aggregate reporting to Congress. Contact Jonathan Thessin with questions.
  • Bureau's Complaint Snapshot Focuses on Debt Collection (6/1/18)
    Twenty-seven percent of total complaints received by the Bureau since 2011 have been debt collection complaints, according to the Bureau's Complaint Snapshot. Consumers reported that there were debts on their consumer credit reports but that they did not have prior written notice of the existence of the debt. Other consumers stated that they felt uncomfortable disclosing personal information to people who called asking for it because they were not sure whether the person calling was a legitimate debt collector. Consumers also complained about the communication tactics companies used when attempting to collect a debt.

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May News

  • ABA's S. 2155 Webinar Now Available for Download (5/30/18)
    More than 2,000 bankers registered for yesterday's webinar with ABA President and CEO Rob Nichols and ABA's top legislative and regulatory experts discussing S. 2155 — the new regulatory reform law — and what it means for banks. The hour-long webinar provided a deep dive into various provisions of the new law and a look at what the industry will tackle next on the path to making commonsense changes to the nation's financial regulatory framework. View ABA’s S. 2155 resources.
  • Mulvaney: Bureau to Consider Scale of Violations in Enforcement Actions (5/30/18)
    The Consumer Financial Protection Bureau will consider the scale of violations as it makes enforcement actions against companies, Bureau Acting Director Mick Mulvaney said at an industry event in Washington, D.C., yesterday. Releases from the Bureau before Mulvaney became acting director would often emphasize the absolute number of violations without describing the overall size of a particular market. "Based upon the information that's given to me, [the rate] was not relevant in the past, but I think it should be," he explained. In one case, for example, a report highlighted 21,000 credit card complaints in 2016, a number that represented a 0.006 percent rate of complaints per open credit card account. In the same speech, Mulvaney announced that the CFPB is developing a "fintech sandbox" to facilitate testing for financial innovations.
  • ABA and State Associations Comment on the Bureau's RFI regarding External Engagements (5/25/18)
    ABA and 51 state trade associations filed a comment letter responding to the Bureau’s request for information on how to engage the public and receive feedback on the work of the agency. We recommended that the Bureau maximize the value of advisory councils and committees; structure outreach meetings to inform policy and regulations; consider industry meetings as an opportunity, not merely a procedural obligation; and enhance outreach to the vendor community. Contact ABA's Krista Shonk with questions.
  • As EU’s GDPR Takes Effect, ABA Unveils Compliance Resources (5/25/18)
    With the General Data Protection Regulation (GDPR) — the European Union's new regulation governing the use of EU personal data — taking effect today, ABA has developed several resources bankers can use to help them approach compliance. While it remains unclear what effect the rule will have on U.S.-based banks offering banking products and services to European customers through internet banking websites, the statute recognizes that non-EU companies operating online that do not "envisage" doing business in the EU, or that inadvertently collect EU personal data, may not be subject to GDPR. ABA will host a free webinar on June 6 that will address what GDPR means for banks and how to comply. Contact ABA's Denyette DePierro for more information.
  • President Trump Signs Landmark ABA-Advocated Regulatory Reform Bill into Law (5/24/18)
    President Trump signed S. 2155 — which was passed earlier this week by a bipartisan majority in the House — into law. The new law is a critical first step toward bringing much-needed regulatory relief to help banks better serve their customers and communities, and came as a result of a persistent, eight-year advocacy effort on the part of bankers, state associations and ABA to address some of the unintended consequences of Dodd-Frank. "Today's signing ceremony concludes years of dedicated advocacy by American Bankers Association members across the country who showed that some of the rules in place were hurting not helping the country," said ABA President and CEO Rob Nichols in a statement thanking the President.
  • OCC Releases Short-Term, Small-Dollar Lending Bulletin (5/23/18)
    The OCC released a bulletin encouraging national banks and federal savings associations to offer responsible short-term, small-dollar installment loans to help meet the credit needs of consumers. "Banks should develop and implement these programs in a manner consistent with sound risk management practices and should align the programs with the banks' overall business plans and strategies," OCC's Bulletin said. ABA welcomed OCC's Bulletin, noting that it is a step in the right direction to help banks offer customers a variety of short-term credit products. "We appreciate that the principles outlined in the bulletin are not prescriptive and encourage banks to design their own underwriting and product features that promote access and treat customers fairly," ABA's Virginia O'Neill said in a statement. Bureau Acting Director Mick Mulvaney also welcomed the OCC's action. "The Bureau will strive to expand consumer choice, and I look forward to working with the OCC and other partners on efforts to promote access and innovation in the consumer credit marketplace," Mulvaney said.
  • Congress Enacts Bipartisan, ABA-Advocated Regulatory Reform Bill (5/23/18)
    In a landmark moment for post-crisis banking policy, the House by a bipartisan 258 to 159 vote on May 22 passed S. 2155, the Senate’s regulatory reform bill. The bill's passage marks an important step toward bringing much-needed regulatory relief to help banks better serve their customers and communities, and President Trump is expected to sign it into law in the coming days. Among the bill's key provisions are several longstanding priorities in the American Bankers Association’s Blueprint for Growth. The bill is a result of a persistent eight-year advocacy effort as bankers worked to bring ideas to Capitol Hill to help address some of the unintended consequences of Dodd-Frank, and ABA emphasized that the bill is a good first step toward reforming the U.S. regulatory architecture. Read ABA's statement.
  • Mulvaney: Bureau to Revisit ECOA Regulations, Submit Guidance for Congressional Review (5/22/18)
    As President Trump on May 21 signed a Congressional Review Act resolution invalidating the Bureau’s 2013 guidance on indirect auto lending, Bureau Acting Director Mick Mulvaney said the Bureau would revisit its Equal Credit Opportunity Act regulations. Mulvaney said the Bureau would work with Congress and other agencies to identify additional guidance that might qualify for repeal under the CRA. "Today's action also clarifies that a number of Bureau guidance documents may be considered rules for purposes of the CRA, and therefore the Bureau must submit them for review by Congress," Mulvaney said. "The Bureau welcomes such review, and will confer with congressional staff and federal agency partners to identify appropriate documents for submission."
  • ABA: Bureau Should Rely More on Supervisory Process, Not Enforcement Actions (5/17/18)
    In a comment letter to the Bureau — the fourth of 12 the association will submit as part of the Bureau's ongoing feedback initiative — ABA called on the Bureau to seek resolution of regulatory violations and compliance management weakness through the supervisory process rather than rushing to enforcement actions. To that end, the association emphasized the need for improved communications; for increased cooperation between the Bureau and the other federal regulatory agencies; more judicious use of Matters Requiring Attention and Potential Action and Request for Response letters; investing in more training resources for Bureau’s examination team; providing forums to help regulated institutions understand the Bureau's Supervisory Highlights publications; and improving the appeals process.
  • Trades Support Fed Proposal to Harmonize Reg J, Reg CC (5/17/18)
    ABA joined three other financial trade groups in offering support for a Federal Reserve proposal to harmonize Regulation J — which governs the collection of checks or other items by Federal Reserve banks and funds transfers through Fedwire — with Regulation CC, which implements the Expedited Funds Availability Act. The groups noted that the Fed's proposal "will help to improve consistency between, and reduce unnecessary duplication within, the two regulations. Contact Nessa Feddis with questions.
  • Temporary Exemption from the CDD rule for CD rollovers and loan renewals (5/16/18)
    Responding to concerns raised by the industry, this afternoon FinCEN announced that it is temporarily suspending the application of the beneficial ownership requirements for CDs rollovers and loan renewals. The Director, Ken Blanco, made the announcement during a House Financial Services Subcommittee hearing on the implementation of the new CDD rule. The relief is retroactive to the mandatory compliance date and will continue for 90 days or until Aug. 9, 2018. During that time, FinCEN will re-evaluate the requirement to determine if more permanent relief is needed. Contact Rob Rowe with questions.
  • Bureau Updates Small Entity Compliance Guides and Guides to Forms (5/16/18)
    The Bureau published updates to both versions of the Small Entity Compliance Guides and Guides to Forms to support the implementation of the 2018 TILA-RESPA Rule. Due to the 2017 TILA-RESPA Rule's optional compliance period, which ends Oct. 1, 2018, the Bureau has kept an old version and new version of each guide to provide implementation support during the optional compliance period. The Bureau updated all versions for the 2018 TILA-RESPA Rule, which is effective before the optional compliance period is over and would apply whether or not you are choosing to comply early with the 2017 Rule.
  • ABA to Bureau: Make Enforcements Fair (5/14/18)
    ABA supports Bureau Acting Director Mick Mulvaney's announcement that the Bureau will rely more on rulemaking and guidance, not regulation by enforcement, ABA wrote in comments to the Bureau's Request for Information on enforcement. ABA suggests, among other things that, the Bureau should provide subjects of an enforcement investigation with the information, time, and attention necessary for them to understand and respond to the Bureau’s concerns and conclusions; rationalize and make transparent its approach to any appropriate Civil Money Penalties by adopting a CMP matrix like the prudential bank regulators; better coordinate with federal and state agencies with relevant jurisdiction; and, carefully match its statements to the press with the language of the related Consent Order. For more information, contact ABA's Virginia O'Neill.
  • Bureau Updates Rulemaking Agenda for Remainder of 2018, Early 2019; See ABA's Staff Analysis (5/14/18)
    The Bureau removed from the list its plans to pursue a rulemaking related to overdraft, which ABA has strongly urged the Bureau to do in previous comments, noting that there was no evidence to support additional regulatory activity in this area. Looking ahead to 2019, the Bureau anticipates issuing a proposed rule on HMDA in January and a proposed rule on small dollar lending in February. In March, the Bureau will begin pre-rulemaking activities on its small business lending rule, propose a rule on third-party debt collection and issue a final rule on the disclosure of confidential information. Contact Jonathan Thessin with questions.
  • OCC Issues New Exam Guidance on Military Lending Act (5/14/18)
    The OCC on Friday issued a new booklet on the Military Lending Act as part of the Comptroller's Handbook. The booklet provides OCC examiners with guidance on examining bank compliance with the MLA amendments finalized in 2015 addressing extensions of credit to service members and their families. It replaces previous MLA guidance. 
  • FinCEN Clarifies Beneficial Ownership Reporting Requirements for Premium Finance Cash Refunds (5/11/18)
    As advocated by ABA, the Financial Crimes Enforcement Network on Friday issued an administrative ruling to provide relief for institutions from applying the beneficial ownership rule to premium finance products that allow for cash refunds. This action exempts these transactions from the rule’s requirement to collect beneficial ownership information.
  • FinCEN's Beneficial Ownership Rule Takes Effect Today (5/11/18)
    As the Financial Crimes Enforcement Network's beneficial ownership rule officially takes effect today, ABA reminds member bankers that they can access a host of resources to facilitate compliance with the rule at aba.com. FinCEN issued a reminder today to financial institutions regarding the rule. For more information, contact ABA's Rob Rowe.
  • ABA Staff Analysis: TRID Final Rule (5/11/18)
    ABA recently issued a members-only staff analysis on the Bureau's final rule aimed at fixing a consequential issue with the TILA-RESPA integrated disclosure (TRID) rules that caused consumers to face significant regulatory delays because of legitimate fee changes during the origination process. The rule takes effect on June 1. For more information, contact Rod Alba.
  • HUD to Seek Public Comment on Disparate Impact Regulation (5/11/18)
    In a move long sought by ABA, the Department of Housing and Urban Development signaled that it will seek public comment on whether its rule implementing the Fair Housing Act's discriminatory effects standard is consistent with the Supreme Court decision in Texas Department of Housing and Community Affairs v. Inclusive Communities Project. ABA and the state bankers associations have long called on the regulatory agencies to include the Supreme Court's reasoning in formal guidance and exam procedures, and have previously committed to collaborating with HUD to develop a rule consistent with the legal precedent set by the Inclusive Communities decision.
  • FinCEN Reminds Filers on Transition to CTR Batch Filing in XML Format (5/9/18)
    The Financial Crimes Enforcement Network reminds batch filers that they must now file using the new XML format no later than June 1. Financial institutions that are unable to do so must revert to the discrete option to file their reports until they are able to file using the new XML format. For questions, please contact the BSA E-Filing Help Desk at 1-866-346-9478 or via email at BSAEFilingHelp@fincen.gov.
  • FinCEN Recognizes Law Enforcement Successes Resulting from BSA Reporting (5/9/18)
    At its annual Law Enforcement Awards ceremony on May 8, the Financial Crimes Enforcement Network recognized several state and federal law enforcement agencies for their work using information reported by financial institutions under the Bank Secrecy Act (BSA) in their criminal investigations. "Industry reporting under the BSA is critical to supporting law enforcement investigations that combat money laundering and other financial crimes," said Treasury Secretary Steven Mnuchin. "Today we are recognizing the tireless efforts of law enforcement to combat financial crimes and thanking them for their partnership. We also appreciate our partnership with the new private sector as they identify and report suspicious activity."
  • House Votes to Overturn CFPB Indirect Auto Lending Guidance (5/9/18)
    The House on May 8 reversed the Bureau’s 2013 guidance on indirect auto lending. In a 234-175 vote, the House passed a Congressional Review Act resolution that would invalidate the guidance, which sought to impose limits on how and what indirect lenders pay car dealers who provide financing and how much discretion dealers have to set loan terms and rates. The Senate previously passed a similar measure to repeal the guidance. In a letter on Monday urging lawmakers to vote for the resolution, ABA noted that the "the regulatory and enforcement uncertainty caused by this guidance has caused many banks to exit or curtail their indirect auto lending, which limits consumer choice and increases the cost of credit."
  • FFIEC Announces Availability of 2017 Mortgage Lending Data (5/8/18)
    The FFIEC on May 7 announced the availability of 2017 data on mortgage lending activity by U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). The data encompasses 12.1 million mortgage applications. Overall, the data showed that total mortgage loan originations declined 12.4 percent to 7.3 million in 2017. This decrease was due to a sharp fall in refinance originations, which fell to 2.5 million as interest rates rose during 2017 from 3.8 million the year before. Meanwhile, originations on loans secured by one- to four-family properties rose from 4 million in 2016 to 4.2 million in 2017. The number of first-lien, owner-occupied home-purchase originations also rose to 3.7 million in 2017, reaching its highest mark since 2007.
  • ABA Issues Policy Recommendations on Fintech (5/7/18)
    As the Treasury prepares to issue its report on nonbank fintech issues, ABA on May 7 released a white paper featuring fintech policy recommendations that would facilitate innovation both inside and outside of the regulated banking system and promote partnerships between banks and nonbanks. Specifically, ABA recommended that regulators: clarify rules to ensure customers can securely share their personal data; think about third-party risk management in innovative ways; provide fintech companies with a path to become banks while ensuring a level playing field; provide a viable process for testing new technologies; modernize how the Community Reinvestment Act is applied; reevaluate the overbroad definition of a brokered deposit; and revisit Regulation D. Contact Rob Morgan with questions.
  • ABA Comments on Bureau RFI re: Administrative Adjudications (5/3/18)
    In a comment letter to the Bureau — the second of 12 the association will submit as part of the Bureau's ongoing feedback initiative — ABA raised concerns about the Bureau's use of administrative adjudications and offered several recommendations for amending its rules of practice for administrative proceedings. The association noted that in the past, the Bureau's approach to administrative adjudications has focused on increasing the scope of its authority, rather than on putting in place checks and balances that ensure that its authority is exercised appropriately and consistently with law and due process. ABA questioned whether the Bureau should have the authority to deny a company the right to defend against an enforcement action in court. For more information, contact Virginia O'Neill.
  • ABA, Chamber, Trades Ask FCC for New TCPA Rules (5/3/18)
    ABA, U.S. Chamber of Commerce, and [10] other members of industry asked the Federal Communications Commission for new rules that would ensure that customers can receive important communications from banks and other businesses. In the joint petition to the FCC, ABA and the other petitioners asked the FCC to issue a new interpretation of a key term in the Telephone Consumer Protection Act — the definition of an "automatic telephone dialing system," commonly known as an "autodialer." For more information, contact Jonathan Thessin.
  • Newest Compliance Column Addresses Changes to Model Form for Beneficial Ownership (5/1/18)
    In the latest issue of the ABA Banking Journal, the Compliance Center Inbox column — authored by ABA's Compliance Hotline experts — answers a question about whether a bank can make changes to the Financial Crimes Enforcement Network's model form to collect beneficial ownership information. The response: a bank can use its own form provided the person opening the account and providing information certifies it is accurate. Other questions in this column address the presumption of privacy between co-applicants in adverse action notices, whether reasons are needed for stop payment orders and whether reminders after marketing letters count as pre-screened solicitations that require an opt-out notice.
  • FHFA Extends Comment Period on FHLB Affordable Housing Program Proposal (5/1/18)
    The Federal Housing Finance Agency extended the comment period on a proposed rule intended to provide the Federal Home Loan Banks greater flexibility in how they manage their affordable housing programs. Comments are now due by June 12. The FHFA also issued a correction to the text of the proposed rule. The new language corrects a calculation that would have prevented affordable housing program funds awarded to the Homeownership Set-Aside Program from being counted toward fulfillment of a proposed regulatory outcome requirement. For more information, contact ABA's Joe Pigg.

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