Client Testimonials

Client Testimonials

“Michael Christians has been a part of the Association’s training programs since 2015. He makes a dull and technically challenging topic both enjoyable and entertaining. He is able to connect with attendees which makes them want to learn more. His experience and knowledge make it easy for attendees to ask questions and get immediate answers. Our credit unions love him! We look forward to bringing Michael back to Mississippi again.”

~ Tom McWilliams, Senior Vice President – Mississippi Credit Union Association

“We hired Michael Christians Consulting, LLC to conduct a Regulation E update training for our plastics card staff. Michael’s perspective on the topic was fresh and new and exactly what we were looking for. He took the time beforehand to discuss the goals of the training so he could specifically tailor the discussion to address our needs. In an ever-changing compliance world, Michael Christians Consulting, LLC is a great resource to have.”

~ Heather Walter, CEO – Jefferson County Federal Credit Union

“We have worked with Michael for the past few years to prepare our annual mortgage loan originator training for front and back office staff. Prior to working with Michael we purchased an off-the-shelf training. The feedback on this off-the-shelf option was poor at best. Michael was able to turn this around for us by building a training course specifically tailored to L&N Federal Credit Union’s needs. With this customized training our staff is more engaged and better able to retain the information presented, all without having their day-to-day work routines significantly interrupted.”

~ Jeff Kempster, Mortgage Lending Manager – L&N Federal Credit Union

“Michael helped to provide valuable expertise in an expedient manner. He presented insight and assistance in the implementation of new regulatory guidance before anyone else. He knew the subject matter, was concise in his interpretation of the guidance and went above and beyond by conversing with our key management team.”

~ Tomasa Marroquin, Compliance Officer

Recent Blog Posts

Texas Court Hits Pause on CFPB's Credit Card Late Fee Rule

By Michael Christians • 14 May, 2024

On Friday, May 10th, Judge Mark Pittman of the United States District Court for the Northern District of Texas granted a preliminary injunction stopping the CFPB's credit card late fee rule from taking effect on May 14th. By way of reminder, the rule would have capped credit card late fees at $8 for large card issuers (those with one million or more open and active credit card accounts). In his opinion, Judge Pittman said that the rule should be stayed pending resolution of CFPB v. Community Financial Services Association of America , a case about whether the CFPB's funding structure is constitutional. That case was argued before the Supreme Court in October 2023, with a decision expected any day. Stay tuned for more details from Michael Christians Consulting, LLC!

Agencies Issue Revised Regulation CC Threshold Adjustments

By Michael Christians • 13 May, 2024

The Federal Reserve Board and the Consumer Financial Protection Bureau have issued the revised Regulation CC thresholds, a full 13 months ahead of schedule. By way of reminder, a 2020 rulemaking indexed several Regulation CC thresholds to inflation. Those thresholds are subject to change on July 1st of every fifth year. Effective July 1, 2025, the following changes will take effect: Increase from $225 to $275 the amount of certain check deposits that must be made available on the next business day following the date of deposit (12 CFR 229.10(c)(1)(vii)) Increase the new account exception hold threshold from $5,525 to $6,725. Beginning 7/1/2025, a financial institution may delay the availability of funds in excess of $6,725 deposited to a new account in any one banking day (12 CFR 229.13(a)(1)(ii)) Increase the large deposit exception threshold from $5,525 to $6,725. Beginning 7/1/2025, a financial institution may delay the availability of funds in excess of $6,725 deposited to an existing account in any one banking day (12 CFR 229.13(b)) Change the definition of repeated overdrafts. Beginning 7/1/2025, an account will be considered repeatedly overdrawn if - On 6 or more banking days within the preceding 6 months, the account balance was negative or would have become negative had checks or other charges to the account been paid, or on 2 or more banking days within the preceding 6 months, the account balance was negative or would have become negative in an amount of $6,725 or more (12 CFR 229.13(d)(2)). You can access the final rule here .

Federal Housing Finance Agencies Announce New ROV Policies

By Michael Christians • 11 May, 2024

Earlier this month, Fannie Mae, Freddie Mac, and FHA announced new requirements for lenders to establish and implement reconsideration of value (ROV) policies and procedures. Fannie Mae and Freddie Mac Lenders must establish policies and procedures that include the steps a borrower can take to appeal an appraisal when they believe the opinion of value is: Unsupported, Deficient due to unacceptable appraisal practices, or Reflects discriminatory appraisal practices. Borrowers must be notified at the time of application and again upon delivery of the appraisal of their right to request an ROV. The new requirements apply to loan applications dated on or after August 8, 2024. Federal Housing Administration Lenders must disclose the following to a borrower at the time of application and again upon delivery of the appraisal: The borrower has the right to initiate an ROV request, The information that he/she will be required to provide in connection with their request, and Expected processing times. The new requirements apply to loans that have an FHA case number assigned on or after September 2, 2024.

Address

5438 South Prairie View Drive

West Des Moines, IA 50266

Phone

319-325-1171

Email

michael@mchristiansconsulting.com

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Michael Christians Consulting, LLC

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