Regulatory Compliance | Michael Christians Consulting, LLC

Regulatory Compliance Support

Michael Christians Consulting, LLC regularly provides support to financial institutions and organizations on consumer compliance issues. By leveraging his experience and knowledge of Federal laws and regulations affecting the financial industry, Michael can help bring significant regulatory relief to your institution or organization.

Counsel Relative to Current Federal Laws and Regulations

Michael Christians Consulting, LLC understands the kinds of issues and questions you face on a regular basis. For over 20 years, Michael has stood shoulder to shoulder with financial institutions and organizations just like yours and watched the industry evolve. He knows exactly where the focus is when it comes to consumer protection matters today, and as a result has targeted his practice to the following Federal laws and regulations:

E-Sign Act
Equal Credit Opportunity Act
Fair Credit Reporting Act
Fair Housing Act
Home Mortgage Disclosure Act
Home Ownership and Equity Protection Act
Homeowner’s Protection Act
Military Lending Act
NCUA Rules and Regulations
Real Estate Settlement Procedures Act
SAFE Act
Servicemember’s Civil Relief Act
Truth in Lending Act
Unfair, Deceptive and Abusive Act and Practices

Strategic Implementation Support for New Regulatory Requirements

Every compliance professional knows that the key to reducing the burden imposed by a new law or regulation is to start early and have a game plan. Michael regularly monitors the activities of the Federal financial institution regulators to give you as much notice as possible about impending requirements. He has successfully helped financial institutions and organizations strategically prepare for significant rule-makings such as the Integrated Disclosure Rule, the Military Lending Act, the TILA/RESPA Mortgage Servicing Rules and the Home Mortgage Disclosure Act.

Policy and Procedure Drafting and Review

Without proper guidance, no organization can function. That’s why Michael Christians Consulting, LLC offers policy and procedure drafting and review customized to your institution or organization. Let us work with you to draft new policies and procedures or have us review existing policies and procedures for deficiencies that may leave your organization vulnerable. Contact Michael today to see how he can help!

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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