Month: June 2020

loan denied stamp

Adverse Action Notice Requirements For Loans and Deposits

When you deny a credit application or a deposit account request, you simply fill out a form and move on to the next customer, right? If only it were that simple! This article will clarify the who, what and why of the different requirements for denying loan applications and deposit requests for consumers and businesses …

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adjustable rate mortgage

LIBOR – CFPB Proposes Amendments to Reg Z to Facilitate Transition

We have all heard that the LIBOR index may no longer be available after 2021 and over the past year TCA has received many questions regarding the transition from the LIBOR. How do we prepare? What is the replacement index? Is there advance notice required? On June 2, 2020, the CFPB released three items related …

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covid-19

Limited Open-End Credit eSign Exemption Due to COVID-19

The Consumer Financial Protection bureau released a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. This is described as a temporary and targeted flexibility for credit card issuers during this pandemic regarding the electronic provision of certain disclosures required to be in writing. Regulation Z generally …

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fraud being stopped

FinCEN Guidance on Medical Scams and COVID-19

As we continue to adjust with the evolving pandemic, FinCEN published two documents to keep awareness high. The May 18, 2020 Notice provides a current update to meet the various BSA reporting, recordkeeping and monitoring requirements.  Here are a few of the key points: BSA Reporting Requirements – As noted in TCA’s earlier article BSA …

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