Monthly Archives:' November 2013

Agencies Increase Consumer Credit, Lease Transaction Thresholds

The Federal Reserve Board (FRB) and CFPB announced an increase in the dollar thresholds in Regulation Z (TILA) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. Transactions at or below the thresholds are subject to the protections of the regulations. Based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers as of June 1, 2013, TILA and Consumer Leasing Act generally will apply to consumer credit transactions and consumer leases of $53,500 or less beginning January 1, 2014. Private education loans and loans secured by real property remain subject to TILA regardless of the amount of the loan.

Regulation M, Regulation Z, and Board Votes

Regulatory Capital Estimation Tool for Community Banks

The federal bank regulatory agencies today released an estimation tool to help community banks understand the potential effects of the recently revised regulatory capital framework on their capital ratios.The revised framework implements the Basel III regulatory capital reforms and certain changes required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The estimation tool is available at:

An earlier version of the Estimation Tool, based upon the proposed version of the Capital Rule, was made available by the Agencies in 2012.  The Agencies noted that the Estimation Tool is intended to be useful for smaller, non-complex banks. The estimation tool is not part of the revised capital framework and not a component of regulatory reporting. Results from the tool are simplified estimates that may not precisely reflect banks’ actual capital ratios under the framework. Additionally, banks should be aware that the estimation tool requires certain manual inputs that could have meaningful effects on results and should reference the revised capital framework when using the estimation tool.

OCC Discusses Bank Secrecy Act

Comptroller of the Currency Thomas J. Curry told a conference on money laundering enforcement that the Bank Secrecy Act is a key element in the fight against illegal drugs and terrorism, and said meeting the challenges of the future will require increased diligence on the part of the industry and government alike.

The development of new payment systems, including digital currencies, creates special challenges, he said in a speech to a conference sponsored jointly by the American Bankers Association and the American Bar Association.

However, “the same technologies that can be exploited for illicit purposes can also be employed to combat money laundering, terrorist financing, and other forms of illicit activity,” he added.  “Perhaps the time has come to explore these sources of technology as a means of providing more accurate, timely, and better information to law enforcement and regulators, and to reduce the significant costs and burdens imposed on banks and other financial institutions.”

Remarks Before the ABA Conference

Financing Business Development, Expansion in Rural USA

The Office of the Comptroller of the Currency (OCC) today published the latest edition of its Community Developments Investments electronic newsletter entitled “Financing Business Development and Expansion in Rural America.” The newsletter provides an in-depth look at how banks are helping rural businesses grow and presents examples of banks helping to finance projects that expand manufacturing and bring services, goods, and jobs to rural communities.  The newsletter also discusses the recent changes to the Interagency Community Reinvestment Act Questions and Answers that will provide banks greater flexibility to serve rural communities that are outside their assessment areas, but are in the broader statewide or regional area that includes their assessment areas. “Banks and thrifts are stretching their financing capacity and reducing their risks by partnering with government agency programs,” said Comptroller of the Currency Thomas J. Curry. “Together, they are meeting community and business needs.”

November 2013 Newsletter

Public Welfare Investments in Wind Energy Projects

The Office of the Comptroller of the Currency (OCC) today published an online newsletter that provides information showing how national banks and federal savings associations can use public welfare investment authority to invest in wind energy projects.

The online newsletter describes how banks and thrifts, with the requisite credit, legal, and accounting expertise, may use the public welfare investment authority to invest in wind energy facilities that create jobs in low- and moderate-income communities, government targeted areas for revitalization, and rural underserved or distressed middle-income communities.

“By serving as investors in wind facilities developed in conjunction with community and economic development projects, banks are able to help to reduce project costs and create jobs in economically targeted areas,” said Comptroller of the Currency Thomas J. Curry. “In some cases, investments in wind energy facilities can help banks meet their Community Reinvestment Act objectives. Banks looking to invest in such activities should ensure that they have the requisite risk systems to manage this type of financing.”

This Community Developments Investments newsletter, “Investing in Wind Energy Using the Public Welfare Investment Authority,” can be accessed on the OCC’s Web site at