Month: August 2018

data graphs

2019 Thresholds under Regulation Z’s CARD Act, HOEPA and QM Sections

Based on the Consumer Price Index in effect on June 1, 2018, which increased 2.5%, the Consumer Financial Protection Bureau (CFPB) released a number of new threshold amounts which go into effect on January 1, 2019. They include:  The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged in …

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personal data

Amid Data Reporting Uncertainty, HMDA Risk Must Be Managed: Part 1—How is it Going?

Now that more than half the year is gone, many banks are starting to look more closely at their new 2018 HMDA LAR requirements because they have adequate volume to do testing. TCA wants to share with you what we have found in doing preliminary HMDA LAR validations. Many of the issues we’ve seen are …

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flood insurance policy

Servicing Compliance Webinar Series: National Flood Insurance Act

Keeping Your Compliance Program Afloat Key webinar topics include: Flood determination timing The Standard Flood Hazard Form. Required coverage calculation Key data on the declaration page Coverage for “abundance of caution” collateral Clarify detached structure requirements Required documentation prior to closing Tracking and monitoring coverage for existing loans Coverage of commercial buildings Definition of a …

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hands on computer keyboard

HMDA 2018 File Format Verification Tool Now Available

Hot on the heels of the release of the HMDA data tables for 2017, the CFPB/BCFP has released its tool for validity checking the correctness of your Institution’s HMDA file for the calendar year 2018 data being submitted in 2019. You can find this tool at https://ffiec.cfpb.gov/tools/file‐format‐verification. The tool does exactly what it says: verifies …

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certificate of deposit

FinCEN Issues Extension of Exceptive Relief for Certificate of Deposit and Loan Renewals

The top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges …

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