The regulators are upping their game and are becoming more familiar with Automated Monitoring Systems. They are starting to push the boundaries of a model validation and their expectations for a “complete” model testing review. Some examiners are more advanced than others, but the word is being spread and soon they’ll all catch on! This […]
Model Validations—Why Do I Need a GAP Analysis? Read More »
Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want
The Expectation of Exceptions in the World of Fair Lending Read More »
The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do
HMDA Reporting Requirements: Business Purpose Loans Read More »
Can your program handle the next data breach? TCA will review the minimum requirements for an ID Theft Prevention Program and consider best practices for staff working with customers who have been victimized. Topics include: Red Flags Risk Assessment ID Theft Prevention Procedures Board Reporting and Governance Vendor Management
Identity Theft and FACT Act Read More »
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