It has been a busy summer from a regulatory compliance perspective, and there is no sign of a slowdown. This article highlights a few items that may otherwise be missed but are worthwhile to take the time to check.

First, either the address or the department name may have changed on some banks’ Summary of Consumer Rights on adverse action notices. The mandatory compliance date was March 20, 2024. The changes are as follows:

• Banks, savings associations, and credit unions with total assets of more than $10 billion and their affiliates: Bureau of Consumer Financial Protection, 1700 G Street NW, Washington, DC 20552
• National banks: Office of the Comptroller of the Currency, Customer Assistance Group, P.O. Box 53570, Houston, TX 77052
• State member banks: Federal Reserve Consumer Help Center, P.O. Box 1200, Minneapolis, MN 55480
• Nonmember insured banks and insured state savings associations: Division of Depositor and Consumer Protection, National Center for Consumer and Depositor Assistance, Federal Deposit Insurance Corporation, 1100 Walnut Street, Box #11, Kansas City, MO 64106

Additionally, some banks that have not previously been required to collect and report data pursuant to the Home Mortgage Disclosure Act (HMDA) may now be HMDA banks. In its Dallas Region Quarterly Newsletter — 1st Quarter 2024, the FDIC noted that the Office of Management and Budget has revised some of the Metropolitan Statistical Areas (MSAs). As a result, some banks that were not previously subject to HMDA may now be. If a bank is one that will become an HMDA reporter, data collection will begin in 2025 to report in 2026.

Recently, the Consumer Financial Protection Bureau (CFPB) extended the compliance dates related to the collection and reporting of small business loan data under the Equal Credit Opportunity Act and Regulation B. The new compliance and reporting dates are as follows:

• Tier One (at least 2,500 covered originations)
  • Compliance Date: July 18, 2025
  • Reporting Date: June 1, 2026
• Tier Two (at least 500 covered originations)
  • Compliance Date: January 16, 2026
  • Reporting Date: June 1, 2027
• Tier Three (at least 100 covered originations)
  • Compliance Date: October 18, 2026
  • Reporting Date: June 1, 2027

Banks are permitted to begin collecting data 12 months prior to their compliance date.

For fair lending, it seems that appraisals will be a big focus. Fannie Mae and Freddie Mac recently published updated Reconsideration of Value (ROV) policies and the FDIC, Federal Reserve, National Credit Union Association (NCUA), Office of the Comptroller of the Currency (OCC), and CFPB released guidance on reconsiderations of value for residential real estate valuations on July 18, 2024. Additionally, the CFPB released its 2023 fair lending annual report to Congress on June 26, 2024.

The Bankers Compliance Task Force will have its next meetings on August 21, 2024, in Flowood, Mississippi, and on August 27, 2024,in Oxford, Mississippi. The meeting will include in-depth HMDA and National Automated Clearing House Association (NACHA) trainings as well as updates on recent changes and releases.