Independent Banker - January 2021 - 34

PORTFOLIO
◎FOCUS COMPLIANCE
A year for
compliance reform
The pandemic may have brought attention away from compliance and
regulatory changes, but some of that may return this year. Regulators
are weighing reforms regarding the Community Reinvestment Act,
Home Mortgage Disclosure Act, Paycheck Protection Program and
more. By Mary Thorson-Wright
hile community bankers had
some long nights in 2020, few
could be chalked up to new regulatory
compliance changes. Looking to 2021
and beyond, a few fi nal compliance
deadlines and several formative
issues will likely shape compliance
requirements for community banks.
Here are the regulatory changes on
the horizon that you should know.
Regulation B and the Paycheck
Protection Program (PPP)
Does Regulation B cover
applications for loan forgiveness
under the PPP? There was no
specific guidance from the CFPB
about Regulation B and the program
since it issued FAQs about the Small
Business Administration's PPP loan
application process in May 2020.
" ICBA's view is, if you are going
to reject applications for PPP loan
forgiveness for any nonqualifying
purpose, the prudent practice is to
comply with Regulation B adverse
action notice requirements, " says
Mickey Marshall, ICBA's director of
regulatory legal aff airs. " While not
technically a loan, it is related to a
loan transaction. "
Community Reinvestment
Act (CRA)
The Offi ce of the Comptroller of the
Currency (OCC) issued a fi nal rule of
CRA changes. The new rules, which
are based on bank type-small and
intermediate, wholesale and limited
purpose, and all other banks-become
eff ective between Oct.1, 2020, and
Jan. 1, 2024. Most rules for small
and intermediate banks became
eff ective this past October. The OCC
rule is primarily based on loan dollar
amounts; bigger loans get more
credit. The rules require all banks to
record, track and report the location
of deposits. Community banks should
evaluate their coverage, capacity for
W
34 Q ICBA Independent Banker Q January 2021
Photo by DNY59/Getty Images

Independent Banker - January 2021

Table of Contents for the Digital Edition of Independent Banker - January 2021

Table of Contents
Independent Banker - January 2021 - Intro
Independent Banker - January 2021 - Cover1
Independent Banker - January 2021 - Cover2
Independent Banker - January 2021 - Table of Contents
Independent Banker - January 2021 - 2
Independent Banker - January 2021 - 3
Independent Banker - January 2021 - 4
Independent Banker - January 2021 - 5
Independent Banker - January 2021 - 6
Independent Banker - January 2021 - 7
Independent Banker - January 2021 - 8
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Independent Banker - January 2021 - 27
Independent Banker - January 2021 - 28
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Independent Banker - January 2021 - 30
Independent Banker - January 2021 - 31
Independent Banker - January 2021 - 32
Independent Banker - January 2021 - 33
Independent Banker - January 2021 - 34
Independent Banker - January 2021 - 35
Independent Banker - January 2021 - 36
Independent Banker - January 2021 - 37
Independent Banker - January 2021 - 38
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Independent Banker - January 2021 - 40
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Independent Banker - January 2021 - 48
Independent Banker - January 2021 - 49
Independent Banker - January 2021 - 50
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Independent Banker - January 2021 - 55
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Independent Banker - January 2021 - Cover3
Independent Banker - January 2021 - Cover4
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