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aRTiCLeS

          The concerns is that these changes could lead to a significant   weaknesses are caused by external problems related to the
          decrease in the number of transcript requests that can be   major disaster and its aftermath.” The agencies also noted that
          processed per day, which could negatively impact consumers.   formal actions normally taken for lower-rated banks “may not
          “Extended processing times will result in delayed closings that   be necessary,” provided the bank has planned appropriately and
          will cause disruption and increase costs for consumers trying to   is on track for recovery.
          purchase or refinance a home loan,” the associations pointed out   The guidance includes instructions for examiners on how to
          in the letter. “Without an immediate resolution, we believe the   assess component ratings for CAMELS or ROCA, focusing
          IRS’ change will begin affecting consumers’ ability to borrow   on losses associated with the disaster, identification of credits
          funds to purchase homes.”
                                                                 affected, prudent planning by management, disaster-related
          While the groups acknowledged the need to protect consumer   effects on earnings and fluctuations in liquidity associated with
          data, they noted that the IRS did not provide sufficient notice   customer cashflow needs.
          to the industry regarding the changes, and did not allow for   To view the guidance visit: https://www.occ.gov/news-
          testing of new systems or processes before they were formally   issuances/news-releases/2017/nr-occ-2017-149a.pdf
          announced.

          To read the letter visit: https://www.aba.com/Advocacy/  Fed Repeals Reg C, Proposes
          LetterstoCongress/Documents/Joint-cl-IRS-MFA121817.pdf
                                                                 Reg M Changes

          FDIC Publishes History of                              The Federal Reserve issued a final rule repealing its Regulation
          Financial Crisis, Regulatory                           C (Home Mortgage Disclosure Act), which has been superseded
                                                                 by final rules issued by the Consumer Financial Protection
          Response                                               Bureau.

          The  FDIC  has  published  a                           The Fed also proposed changes to Regulation M – which
          history of the financial crisis and                    governs consumer leasing – to clarify the scope of the board’s
          how the agency responded to it.                        supervisory authority following changes under the Dodd-Frank
          Covering the period between                            Act and Consumer Protection Act. Comments on the proposal
          2008 and 2013, the publication examines the agency’s response   will be due 60 days after publication in the Federal Register.
          efforts and shares lessons learned.
                                                                 To read the proposed rule on Reg M visit: https://
          To read more visit: https://www.fdic.gov/bank/historical/  www.federalreserve.gov/newsevents/pressreleases/files/
          crisis/index.html                                      bcreg20171218a2.pdf

          Banking Agencies Issue                                 Treasury Extends Farm Credit

          Guidance on Supervision after                          System Line of Credit Into
          Disasters                                              2018

          In the wake of record-setting hurricane and wildfire seasons,   Without providing public notice,
          the federal banking agencies have issued new guidance on   the Treasury Department recently
          how examiners will approach financial institutions affected   renewed the Farm Credit System’s
          by major natural disasters. The agencies noted that when   $10 billion line of credit through
          evaluating composite ratings for institutions, examiners should   its Federal Financing Bank (FFB)
          review management’s overall response and recovery planning.   through September 30, 2018, Bert
          The agencies also said they would work with institutions to   Ely reported in the latest edition of
          determine needs, reschedule exams and extend deadlines as   Farm  Credit  Watch.  “Technically,
          needed.                                                the parties to this line of credit are
          “The examiner’s assessment may result in assigning a lower   the FFB and the Farm Credit System Insurance Corporation,
          component or composite rating for some affected institutions,”   the FCS entity which insures the Systemwide Debt Securities
          the agencies said. “However, in considering the supervisory   issued by the Federal Farm Credit Banks Funding Corporation.
          response for institutions accorded a lower rating, examiners   Those securities fund the bulk of the FCS’ balance sheet,”
          should give appropriate recognition to the extent to which   totaling $257.9 billion as of September 2017, Ely said. He
                                                                 added that “unlike a line of credit issued by a commercial bank,




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