KEY BANKING PROVISIONS OF S.

2155--
BIPARTISAN REGULATORY RELIEF BILL
PROVISIONS BY
NO ASSET RESTRICTION 18-month exam cycle, up from $1
BANK SIZE
• TRID Relief: Removes three-day billion.
BANK SIZE
waiting period required under BANKS UNDER $5 BILLION
TILA-RESPA mortgage disclosure
• Short-Form Call Report: Agencies
when creditor extends a second required to reduce reporting
offer of credit with lower APR. requirements for the first and
• Appraisal Requirement third quarters for banks that
Exemption: Exemption for rural meet appropriate criteria.
mortgage portfolio loans of less
BANKS UNDER $10 BILLION
than $400,000 if unable to find a
• QM Relief: Certain mortgage
state-certified/licensed appraiser
loans originated and retained in
to perform the appraisal in a
portfolio deemed to be qualified
timely manner.
mortgages.
• Reciprocal Deposits: Certain
• Escrow Requirement Exemption:
reciprocal deposits will not be
Exemption from TILA escrow
considered brokered deposits.
requirement for banks that make
• HMDA Exemption: Exemptions 1,000 or fewer first lien
from collecting the new Dodd- mortgages on principal dwellings.
Frank Act data fields for banks
• Capital Simplification: Agencies to
with “satisfactory” CRA ratings
establish a tangible equity
that originate fewer than 500
leverage ratio between 8-10
closed-end mortgage loans or
percent; banks exceeding the
fewer than 500 open-end lines of
ratio meet risk-based capital and
credit.
leverage requirements and are
BANKS $3 BILLION OR LESS “well-capitalized.”
• Fed’s Small BHC Policy: Raises the
• Volcker Rule Exemption: Banks
Federal Reserve’s Small Bank with total trading assets and
Holding Company Policy liabilities not exceeding 5 percent
Statement’s asset threshold from of total assets exempt from the
$1 billion to $3 billion. Volcker rule.
• Exam Cycle: Well-managed, well-
BANKS $10 BILLION-$50 BILLION
capitalized banks qualify for
• DFAST Eliminated: These

www.icba.org/advocacy March 2018

 institutions no longer subject to • Treatment of Municipal Bonds in and the U.S. capital markets.
mandatory Dodd-Frank Act stress Liquidity Coverage Ratio:
• Identity Fraud Prevention: Social
testing. Agencies directed to classify Security Administration to accept
investment-grade muni bonds as
• Risk Committees: These publicly electronic consumer consent for
level 2B liquid assets under the
held institutions no longer banks verifying customer identity,
LCR rule.
required to have a risk to combat “synthetic” identity
committee. FEDERAL SAVINGS INSTITUTIONS; fraud.

BANKS $50 BILLION-$100 BILLION MUTUAL HOLDING COMPANIES • Medical Debts of Veterans:
• DFA Prudential Standards: On • Federal Savings Associations: Certain medical debts incurred by
enactment date, these Institutions with assets of $20 veterans excluded from
institutions will be exempt from billion or less can elect to operate consumer reporting under FCRA.
the Dodd-Frank enhanced with national bank powers.
• Servicemember Foreclosure
prudential standards. • Mutual Holding Company Protection: Foreclosure relief
BANKS $100 BILLION-$250 BILLION Dividend Waiver: To waive provisions for servicemembers
dividends of subsidiaries, mutual made permanent.
• DFA Prudential Standards:
holding company members must
Eighteen months after date of • VA Loans: VA lenders required to
have voted to do so in the prior
enactment, these institutions will demonstrate a material benefit
24, rather than 12, months.
be exempt from the Dodd-Frank to the borrower when
enhanced prudential standards, OTHER refinancing their mortgage.
other than stress testing. • Credit Freezes: Credit bureaus to
• Credit Score Models: Fannie
However, the Fed will have the provide consumers with free
Mae/Freddie Mac to establish
discretionary authority to apply security freezes, and active duty
process for validating and
the standards to these banks. service members with free credit
accepting alternative credit score
BANKS UNDER $250 BILLION monitoring, upon request.
models.
• Capital Treatment of HVCRE: • Elder Financial Abuse:
• Mortgage Licensing:
Acquisition, development and Protections for certain bank
Registered/licensed loan
construction loans that meet employees who disclose the
originators given temporary
certain criteria will not have suspected exploitation of a senior
authority to act under SAFE
higher risk-weights under risk- citizen to a regulatory or law-
Mortgage Licensing Act when
based capital rules. enforcement agency.
changing employers.
• Cyber Threats: Treasury to
BANKS OVER $250 BILLION study/report on the risks of cyber
threats to financial institutions • Manufactured Housing: TILA

www.icba.org/advocacy 2
 amended to exclude as a their obligations upon death of
“mortgage originator” an student borrower.
employee of a retailer of
• Financial Literacy: Treasury to
manufactured/modular homes
establish non-binding best
who does not receive practices for colleges regarding
compensation from residential
financial literacy to assist
mortgage loan applications. students making borrowing
• Renters’ Protection: The decisions.
Protecting Tenants at Foreclosure
• Credit Union Lending: Loans
Act (sunset in 2014) permanently
secured by 1- to 4-family
restored. dwelling, that is not the primary
• PACE Loans: Real property residence of a member, is not a
retrofit (PACE) loans subject to member business loan under
consumer protections. Federal Credit Union Act.

• Asbestos Hazards: Treasury Dept. • Bank Mutual Funds: Certain funds

authorized to use loan able to share the same name as
guarantees and credit their bank-affiliated investment
enhancements to remediate lead adviser.
and asbestos hazards in
residential properties.

• Appraisal Services: Appraisal

services donated by fee
appraisers as charitable
contributions will be “customary
and reasonable” under TILA
(Habitat for Humanity).

• Student Loans: Private student

lenders may not declare default
against student borrowers due to
death or bankruptcy of co-signer.
Co-signers are released from

www.icba.org/advocacy 3