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CFPB Delays TRID Implementation

June 17, 2015

The Consumer Financial Protection Bureau (CFPB) has delayed implementation of the new TILA-RESPA Integrated Disclosure (TRID) by two months until October 3, 2015. The CFPB said it took the action due to an administrative error and to better accommodate consumers and providers.

On June 2, 2015 CBAI submitted a comment letter to the CFPB urging the Bureau to allow for a period of restrained enforcement and liability (a grace period) for community banks attempting to comply in good faith with the regulations between the [original] August 1st effective date and through year-end 2015.

While CBAI is pleased that the original extension date has been extended to October 3rd, we will none-the-less be advocating for an additional grace period which is not without precedent and will be beneficial to customers and community banks. Read June 2 CBAI Comment Letter.

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CBAI Opposes FCA’s Farmer Mac Proposal

June 23, 2015

The Community Bankers Association of Illinois is urging the Farm Credit Administration to withdraw a corporate governance and standards of conduct proposal which would require Farmer Mac board members to have a substantial and visible connection with a voting stockholder. In CBAI's opinion, this provision is an attempt by Farm Credit to require Farmer Mac’s directors to be subject to outside influences and control. CBAI is concerned that this requirement would not contribute to Farmer Mac’s ability to fulfill its mission nor would it promote safety and soundness. Read CBAI Comment Letter.

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Victory in U.S. Supreme Court Case That Was the Subject of CBAI Amicus Brief

The Community Bankers Association of Illinois (“CBAI”) is thrilled with the U.S. Supreme Court’s June 1 decision resolving the case of Bank of America, N.A.v. Caulkett and with the efforts of CBAI Associate Member law firm SmithAmundsen LLC in preparing an amicus brief on behalf of CBAI and CBAI’s members throughout Illinois. The victory in this decision protects the secured interests of junior lienholders in bankruptcy cases, and CBAI believes that the arguments submitted in the amicus brief were reflected in the Court’s opinion. A big “thank you” to SmithAmundsen LLC, including Michael Cortina and John Collen, who guided CBAI through the amicus drafting and kept CBAI apprised of the status of the case. The Caulkett decision is a big victory for junior lienholders. Click here to review more about the case and the Supreme Court’s opinion.

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CBAI Urges a Grace Period in TRID Implementation

June 3, 2015

The Community Bankers Association of Illinois urges the Consumer Financial Protection Bureau to increase the likelihood of a successful implementation of the TILA-RESPA Integrated Disclosure (TRID) by allowing for a period of restrained enforcement and liability (a grace period) for community banks attempting to comply in good faith with the new regulations between the August 1st effective date through year-end 2015.

Given the complex nature of integrating the forms and a lack of live testing, unintended consequences can undoubtedly be expected which will complicate the home purchase and residential mortgage finance process. In addition, a period of restraint, when combined with a good faith attempt to comply, is not without precedent. CBAI believes the use of a grace period in implementing the TRID is necessary and will be beneficial to consumers and community banks. Read Letter.

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CBAI Applauds Legislation to Break Up TBTF Banks

June 1, 2015

CBAI expressed thanks in a recent letter to Senator Bernie Sanders (I-VT) for introducing legislation which requires breaking up the nation’s mega banks (S. 1206 – The Too Big to Fail, Too Big to Exist Act). Too-big-to-fail remains one of CBAI’s top Federal Policy Priorities. In a complete statement on this important issue, CBAI concludes that these banks have repeatedly proven, at an incredible cost to community banks and their communities, our financial system, the economy, and American taxpayers, that they are clearly too-big-to-behave and must be downsized. Read CBAI Letter.