David Mulkerin

Question and Answer

An institution allows service charges to overdraw our checking accounts but not our savings accounts. Should that be in our disclosures somewhere?

Answer: The FDIC has been criticizing Institution’s for not disclosing this possibility. Under Regulation DD, Institutions are required to disclose what can cause overdrafts. The typical language is: Overdraft fees apply to overdrafts created by check, in-person withdrawal, ATM withdrawal, or other electronic means. TCA recommends additional changes based on whether or not the Institution

An institution allows service charges to overdraw our checking accounts but not our savings accounts. Should that be in our disclosures somewhere? Read More »

Important Announcement

New Threshold Amounts for 2025 under Regulation Z CARD Act, HOEPA and QM Sections

Based on the 3.4% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2024, the Consumer Financial Protection Bureau (CFPB) released a few new thresholds which go into effect on January 1, 2025. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 3.4% increase in

New Threshold Amounts for 2025 under Regulation Z CARD Act, HOEPA and QM Sections Read More »

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SAFE Act MLO Registration Renewal Period Starts November 1 – Check Current Registrant’s Names

It’s that time again. The NMLS 2024 Annual Renewal Period began on November 1 and will end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their

SAFE Act MLO Registration Renewal Period Starts November 1 – Check Current Registrant’s Names Read More »

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2025

On October 4, 2024, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections

HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2025 Read More »

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

Phone

800-934-REGS

Email for Non-Confidential Information Only

[email protected]

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

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