October 2017 A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
2 ABA Supports Fix to
TRID Black Hold
3 CFPB Harmonizes
Regs B and C
3 Agencies Issue Key
HMDA Data Fields
4 Technical Changes
to Servicing Rule
4 Principles for 3d-
Party Data Access
5 ABA Files Suit on
5 CFPB Rushing
6 No Delay on Credit
Card MLA Rules
6 OCC Aligns Exam
Ratings with CRA
6 ABA Supports CRE
7 ABA Supports
7 Education Dept.
CFPB FINALIZES SMALL-DOLLAR LENDING RULE –
ABA WINS ACCOMMODATION LOAN EXEMPTION
ABA won a helpful exemption in the Consumer Financial Protection Bureau’s final
small-dollar lending rule that protects banks’ ability to make small-dollar
“accommodation loans” to customers. The Bureau on October 5 finalized its long-awaited rule to curtail short-term, small-dollar consumer loans. Under the final rule –
as ABA advocated in its comment letter – small-dollar loans will be exempt entirely
from the rule, provided they are made by a lender that has made fewer than 2,500 of
these loans in each of the current and previous years and for whom these loans
account for less than 10 percent of revenues.
The accommodation loan exemption applies regardless of the size of the lender
offering it. In addition, for banks that exceed the threshold for the accommodation loan
exemption, the final rule preserves the ability of these banks to offer installment loans
of 46 days or more, which ABA believes will allow banks to innovate and increase their
responsible small-dollar credit products.
“With today’s rule, the Bureau has reiterated its earlier view that banks can play an
important role in meeting the needs of small-dollar borrowers,” said ABA‘s Ginny
O'Neill. “As we continue to analyze the final rule’s 1,690 pages, we hope that it will
allow banks to expand programs to effectively meet the small-dollar credit needs of
ABA will continue to review the final rule, which covers a wide swath of small-dollar
loans of 45 days or less, including payday loans, auto title loans, deposit advances
and longer-term loans with balloon payments – all of which are subject to an ability-to-
Notice to Our Readers
ABA Bank Compliance newsletter will publish its final issue in November 2017.
Subscribers will continue to have access to past issues.
ABA Bank Compliance magazine is unaffected and will continue on its regular,
To keep up with compliance issues, readers employed at ABA member banks can
request to receive ABA’s Daily Newsbytes, the Compliance, Anti-Money
Laundering and Risk & Cybersecurity Email Bulletins, as well as access to ABA’s
Compliance and Bank Risk Networks.
The ABA thanks Cristeena Naser for serving as editor of this publication since 1997
and wishes her well in her upcoming retirement.