Joint intent exceptions are a common finding in our compliance reviews. We have found that there are misconceptions on what constitutes joint intent and how it should be documented; most of the questions come from commercial versus consumer mortgage loan officers. Many of the questions we are asked include: Isn’t the joint financial statement enough …
Clarifying the Joint Intent Requirements at Application Read More »
The expectation for enhanced due diligence did not change with the passing of the 5th BSA pillar. However, examiner expectations for enhanced due diligence (EDD) continue to evolve because it is a critical component of your bank’s BSA Program. TCA® first addressed the EDD topic in a 2015 In Depth article. The November 2018 BAT …
What do CDD and EDD Mean? Part II: Enhanced Due Diligence Read More »
The passing into law of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) provided institutions with a partial exemption of some data fields under HMDA. One of the fields in the exemption is the Universal Loan Identifier (ULI) and allows institutions to report a Non-Universal Loan Identifier (NULI). The difference between the two …
There’s an old saying, “You don’t know what you don’t know” and that is certainly true when it comes to marketing initiatives meshing with the world of fair lending. The clash of both worlds and the often-divergent priorities have caused regulators to put this intersection under a microscope. A key fact today is that marketing …
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