Month: April 2020

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HMDA Reporting Threshold Changes for 2020 and Beyond

On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. To assist with understanding the transition, the Bureau has published new resources and updated some existing ones: Unofficial, informal redline to reflect changes to Regulation C Executive Summary HMDA Rule Key Dates Timeline 2020-2022 HMDA institutional coverage chart, effective …

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Agencies Release Interim Final Rule on Deferral of Appraisals/Evaluations

On April 14, 2020 the OCC, FRB and FDIC issued an interim final rule effective April 17, 2020 until December 31, 2020 (comments due June 1, 2020) which will amend the agencies’ regulations requiring appraisals of real estate for certain transactions. (NOTE: This rule was finalized on October 16, 2020.) Under the interim final rule, …

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BSA Compliance & COVID-19: FinCEN & SBA Updates

Over the past month, every facet of our lives has dramatically changed. Shelter-in-place orders, rotating bank staff, lobby closures, government stimulus programs and a myriad of regulatory updates have stretched risk management resources. TCA has received many questions from clients asking for our interpretation of guidance that has been issued in response to these regulatory …

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Uncovered Fair Lending Demographic Data Flaw

The Consumer Financial Protection Bureau (CFPB) mandated changes to the collection of HMDA dataset information which was implemented in 2018. Significant changes were made in the areas of Ethnicity and Race which impacts the fair lending analysis process. In 2018 and going forward, Ethnicity and Race require additional information be available on the dataset form …

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Considerations for Managing an Offsite Review

They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the …

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