Share on LinkedInShare on LinkedIn

ARTICLE · 28 NOVEMBER 2017

Banking Agencies Adjust Thresholds For Small Loans

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Contributor
Hogan Lovells Cadwalader

Hogan Lovells Cadwalader

Hogan Lovells Cadwalader is a global law firm trusted by clients to deliver on complex, high-stakes...

View firm profile
Explore more from Hogan Lovells Cadwalader

The Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau and the Office of the Comptroller of the Currency issued a final rule and interpretation...

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Author LinkedIn connections

The Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau and the Office of the Comptroller of the Currency issued a final rule and interpretation announcing that the threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans during 2018 will increase from $25,500 to $26,000. The new threshold, which is based on the Consumer Price Index for Urban Wage Earners and Clerical Workers ("CPI-W"), will become effective on January 1, 2018.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Read more about

Related Comparative Guides

See more popular content from

Article

Consolidation = Control: The GAAP Presumption Under Regulation W

When determining affiliate relationships under Regulation W, the Federal Reserve provides a critical bright-line rule: if a company consolidates another on its U.S. GAAP financial statements, it is presumed to have controlling influence. This presumption offers compliance officers a practical starting point for identifying control relationships, though other factors beyond GAAP consolidation can also establish regulatory control.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

SEC Proposes Rescission Of Investment Adviser Pay-to-Play Rule

The SEC has proposed rescinding Rule 206(4)-5 under the Investment Advisers Act, which currently prohibits certain political contributions and restricts the use of placement agents for soliciting government investors. The proposal addresses concerns about the rule's strict-liability standard, overbroad definitions, and disproportionate penalties for inadvertent violations, while raising questions about whether existing safeguards and state laws provide sufficient protection against pay-to-play practices.
United StatesFinance and Banking
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

From Legislation To Implementation: Arizona’s SAID Act Takes Effect

Arizona's new State Affordability Infrastructure District framework becomes operational on September 14, creating unprecedented opportunities for developers to finance public infrastructure through a statewide vehicle. As the first formation petitions are prepared, critical decisions about district boundaries, financing structures, and bond capacity will determine the success of projects across the state.
United StatesFinance and Banking
Taft, Stettinius & Hollister LLP
Taft, Stettinius & Hollister LLP
Article

SEC Moves To Scrap Pay-to-Play Rule

The SEC has proposed rescinding its controversial pay-to-play rule for investment advisers, a regulation that has imposed strict penalties on firms for even minor political contribution violations since 2010. While the rule was designed to prevent corruption in the selection of advisers for government pension funds, critics argue it has created unintended consequences including suppression of political speech, hiring difficulties, and disproportionate penalties for inadvertent mistakes.
United StatesFinance and Banking
Lowenstein Sandler LLP
Lowenstein Sandler LLP
Article

Eleventh Circuit Holds FCA Qui Tam Litigation Does Not Violate The Appointments Clause In Article II Of The U.S. Constitution – But Questions Remain

The Eleventh Circuit's reversal in U.S. ex rel. Zafirov v. Florida Medical Associates addresses one of the most anticipated False Claims Act decisions in years, ruling that qui tam provisions do not violate the Appointments Clause. While this decision aligns with other circuit courts, it leaves critical constitutional questions unresolved, including Take Care and Vesting Clause challenges that could reshape FCA litigation.
United StatesLitigation, Mediation & Arbitration
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

Trump Executive Order Targets Foreign-Sourced Bulk-power Equipment, Expands Department Of Energy Authority

President Trump's Executive Order 14421 declares a national emergency targeting foreign-produced equipment in the U.S. bulk-power system, granting the Secretary of Energy sweeping authority to review, restrict, and potentially require replacement of equipment linked to countries under U.S. arms embargoes. While no immediate restrictions take effect, the Order's broad scope encompasses battery storage systems, utility-scale inverters, industrial control systems, and related software, with implementation regu
United StatesEnergy and Natural Resources
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

OCC And FDIC Put Guardrails Around “Unsafe Or Unsound” Practices And MRAs

The OCC and FDIC have jointly finalized a rule that fundamentally redefines what constitutes an "unsafe or unsound practice" in banking supervision, establishing new binding standards for when examiners may issue matters requiring attention. This regulatory shift aims to concentrate supervisory attention on material financial risks rather than procedural deficiencies, while providing banks with stronger grounds to challenge supervisory findings that lack connection to substantive financial harm.
United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

The California Air Resources Board Launches Voluntary Reporting Platform And Issues New Guidance Ahead Of Pending November 10, 2026, SB 253 Reporting Deadline

California's Air Resources Board has released comprehensive guidance for entities preparing their first greenhouse gas emissions reports under SB 253, introducing a voluntary reporting platform and clarifying expectations for the November 2026 deadline. The guidance addresses critical questions about data collection requirements, assurance standards, and enforcement discretion for companies that weren't tracking emissions as of December 2024. Understanding these reporting parameters and submission options w
United StatesEnvironment
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

Delaware Court Of Chancery Reinforces High Bar To Plead Existence Of A Control Group And Dismisses Action Challenging Take-private Acquisition

The Delaware Court of Chancery dismissed a class action challenging Vista Equity Partners' take-private acquisition of KnowBe4, Inc., finding that plaintiffs failed to adequately allege a control group among institutional investors and the CEO. The decision examines stringent pleading standards for control groups and demonstrates how a fully informed stockholder vote can cleanse transactions involving director-level conflicts, even when entire fairness review would otherwise apply.
United StatesCorporate/Commercial Law
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

Quorum: Boardroom Insights Into Governance, M&A, And Securities Law – September 2026

This September 2026 edition of Quorum examines critical developments in corporate governance, M&A transactions, and securities regulation, including Delaware Court decisions on strategic investor rights and control group standards, new SEC guidance on beneficial ownership reporting, and Supreme Court rulings on disgorgement remedies. The newsletter also analyzes FTC perspectives on vertical mergers in defense sectors and provides comprehensive updates on the SEC's 2026 regulatory agenda under Chairman Atkin
United StatesCorporate/Commercial Law
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

U.S. Supreme Court Rejects Investor Loss Requirement For SEC Disgorgement

The U.S. Supreme Court has unanimously ruled that the SEC may obtain disgorgement without proving investors suffered financial losses, resolving a circuit split in favor of the Commission. While the majority opinion preserves disgorgement as a powerful enforcement tool, Justice Thomas's concurrence raises fundamental questions about whether disgorgement has become a legal remedy triggering Seventh Amendment jury trial rights.
United StatesCorporate/Commercial Law
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

Divided FTC Statements In IonQ/SkyWater Reward Close Study By Parties To Vertical And Defense-Sector Transactions

The Federal Trade Commission closed its investigation of IonQ's acquisition of SkyWater Technology after the Commission's two sitting members divided over whether the transaction warranted a negotiated behavioral consent order. These detailed statements reveal how each Commissioner analyzes vertical transactions and their claimed benefits, offering critical insights for parties planning vertical transactions in defense and national-security sectors.
United StatesAntitrust/Competition Law
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Article

Strategic Investor Rights, Shared Risks: Governance Requirements When Interests Diverge

A Delaware Court of Chancery opinion examines the boundaries of strategic investor rights in a case involving alleged misuse of contractual governance and veto powers. The decision explores when an investor's board designee crosses the line from legitimate oversight into disloyal conduct, and whether contractual rights shield investors from liability when they allegedly deploy those rights to harm a company for competitive advantage.
United StatesCorporate/Commercial Law
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader