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Recent Final Rule Analyses
Final Rule Analysis: FHA Risk Reduction Final RuleThe Department of Housing and Urban Development has issued a final rule that changes certain policies that are intended to reduce the risk of loans insured by the Federal Housing Administration (FHA). The final rule will change the credit score requirements, although the FHA has included a temporary exemption for borrowers who refinance current loans.
Final Rule Analysis: NCUA Issues Final Rule for Short-Term, Small Amount LoansThe National Credit Union Administration has issued a final rule that will enable federal credit unions (FCUs) to offer short term, small amount (STS) loans as a viable alternative to predatory payday loans that are offered by other financial service providers. This final rule will permit FCUs to charge an interest rate that is higher than the current usury ceiling in the Federal Credit Union Act, but will impose limitations on the permissible term, amount, and fees for these types of loans. The final rule also identifies certain “best practices” that FCUs should incorporate into their individual STS loan programs.
Final Rule Analysis: Agencies Issue Guidance for Reverse MortgagesThe Federal Financial Institutions Examination Council (FFIEC) has issued guidance for reverse mortgages titled Reverse Mortgage Products: Guidance for Managing Compliance and Reputation Risks (Guidance). The National Credit Union Administration, along with other federal financial institution regulators, is a member of the FFIEC and the Guidance will apply to federally-insured credit unions.
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