FSOC: Advanced Notice of Proposed Rulemaking Regarding the Authority to Designate Financial Market Utilities as Systemically Important

Published Proposal: Not published yet
Comments Due: Late December, T.B.D.
Disposition: Pending

Summary of the Proposed Rule:
In the Dodd-Frank Act (DFA), the Financial Stability Oversight Council (FSOC) is given authority to identify and designate important financial market utilities (FMUs) as systemically important if the disruption or failure of those entities would cause, or create an increased risk of, significant credit or liquidity risk to financial institutions or markets.  If an FMU is determined to be systemically important it would be subject to additional oversight by regulators.

The DFA defines FMUs as any person that manages or operates a multilateral system for the purpose of transferring, clearing, or settling payments, securities or other financial transactions.  The DFA explicitly excludes designated contract markets and national security exchanges from the definition of FMU.

The advanced notice of proposed rulemaking (ANPR), released by the FSOC on November 23, 2010, asks for comment on ten questions about the criteria and analytical framework that should be applied by the FSOC when designating FMUs. The questions involve, among other things, measuring and assessing the aggregate monetary value of transactions that financial market utilities process, and also the aggregate exposure of such utilities engaged in payment, clearing, or settlement activities to their counterparties. 

This ANPR does not address the designation criteria and framework for payment, clearing, or settlement activities performed by financial institutions.  That will be considered in a separate rulemaking.

 


FinCEN: Proposal on New Reports of International Wire Transfers

ABA Contact: Rob Rowe
Published Proposal: 75 Federal Register 60377; September 30, 2010
Comments Due: December 29, 2010
Disposition: Pending

Summary of the Proposed Rule:
Section 6302 of Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA) directed the Secretary of the Treasury to study the feasibility of "requiring such financial institutions as the Secretary determines to be appropriate to report to Financial Crimes Enforcement Network (FinCEN) certain cross-border electronic transmittals of funds (CBETF), if the Secretary determines that reporting of such transmittals is reasonably necessary to conduct the efforts…against money laundering and terrorist financing."

Over the last six years, FinCEN has extensively analyzed the costs and benefits of such a reporting requirement and, concluding the data would be useful for law enforcement, has now issued a proposal on  CBETF. When final, the rule would require depository institutions and money services businesses (MSBs) to report information on wire transfers. Reports would be made by the last institution handling certain electronic funds transfers before it leaves the United States or the first institution that receives a wire from outside the country. The proposal is the first step in a multi-phase project. At least during this first phase of reporting, internal transfers, ACH, ATM and POS transactions would be exempt. In addition to the regular reports on CBETF, all banks would be required to submit an annual report of a list of taxpayer identification numbers of accountholders who transmitted or received CBETF

 


FRB: Interim Final Appraisal Rule

Published Proposal: 75 Federal Register 66554; October 28, 2010
Read ABA's Staff Analysis, November 1, 2010 
Comments Due: December 27, 2010
Disposition: Pending

Summary of the Proposed Rule:
The Federal Reserve on October 18 issued an interim final rule under the Dodd-Frank Act that is intended to ensure that real estate appraisers can use their independent judgment in assigning home values. The rule also includes several provisions designed to protect the integrity of the appraisal process when a consumer's home is securing the loan. The rule prohibits coercion and similar actions designed to cause appraisers to base the appraised value of properties on factors other than their independent judgment, and prohibits creditors from extending credit based on appraisals if they know beforehand about violations involving appraiser coercion or conflicts of interest. Finally, the rule requires the payment of reasonable and customary compensation to appraisers. The rule is effective April 1, 2011. Read the Fed's October 18 press release.

 


FRB: TILA/Reg Z Proposal to Update/Clarify Rules Regarding Right of Rescission, Disclosures for Loan Modifications, Classification of HPML, Customer Refund of Fees, Reverse Mortgage Issues, Etc.

Published Proposal: 75 Federal Register 58539; September 24, 2010
Comments Due: December 23, 2010
Disposition: Pending
Read ABA's Staff Analysis.

Summary of the Proposed Rule:
The Board proposes to amend Regulation Z, which implements the Truth in Lending Act (TILA), and the staff commentary to the regulation, as part of a comprehensive review of TILA's rules for home-secured credit. This proposal would revise the rules for the consumer's right to rescind certain open-end and closed-end loan secured by the consumer's principal dwelling. In addition, the proposal contains revisions to the rules for determining when a modification of an existing closed-end mortgage loan secured by real property or a dwelling is a new transaction requiring new disclosures. The proposal would amend the rules for determining whether a closed-end loan secured by the consumer's principal dwelling is a ''higher-priced'' mortgage loan subject to the special protections in § 226.35. The proposal would provide consumers with a right to a refund of fees imposed during the three business days following the consumer's receipt of early disclosures for closed-end loans secured by real property or a dwelling.

The proposal also would amend the disclosure rules for open- and closed end reverse mortgages. In addition, the proposal would prohibit certain unfair acts or practices for reverse mortgages. A creditor would be prohibited from conditioning a reverse mortgage on the consumer's purchase of another financial or insurance product such as an annuity, and a creditor could not extend a reverse mortgage unless the consumer has obtained counseling. The proposal also would amend the rules for reverse mortgage advertising.