August 2019

regulation z

New Threshold Amounts for 2020 under Regulation Z CARD Act, HOEPA and QM Sections

Special Release / By

Based on the 1.9% increase in the Consumer Price Index in effect on June 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2020. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. (1026.6(b)(2)(iii) and […]

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audit

Examiners Stress Independent Audit Critical to BSA Success

AMS Model Reviews, BSA/AML, Special Release / By

On July 22, 2019, the prudential regulators issued FIL-43-2019 making a joint statement on BSA/AML risk-based approaches in examinations. TCA’s BAT reviewed the statement and took away three key points: transparency, risk assessment and independent audit. Transparency – The statement states: “This statement is intended to improve transparency into the risk-focused approach used for planning

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