ARTICLE · 15 OCTOBER 2024

OCC Issues Bulletin On Refinance Risk In Commercial Lending

Goodwin Procter LLP

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In this issue. The Office of the Comptroller of the Currency (OCC) issued guidance for managing refinance risk in commercial lending; the Consumer Financial Protection Bureau (CFPB)...

United StatesFinance and Banking

Josh Burlingham

William McCurdy

In this issue. The Office of the Comptroller of the Currency (OCC) issued guidance for managing refinance risk in commercial lending; the Consumer Financial Protection Bureau (CFPB) released its 35th issue of Supervisory Highlights with a focus on auto finance; the CFPB and the Board of Governors of the Federal Reserve System (Federal Reserve) announced updated dollar thresholds for consumer credit and lease transactions under Regulation M and Regulation Z; and the CFPB, Federal Reserve, and OCC announced increased appraisal thresholds for certain higher-priced mortgage loans. These and other developments are discussed in more detail below.

Regulatory Developments

OCC Issues Bulletin on Refinance Risk in Commercial Lending

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