Answer: The sunset of the LIBOR has been delayed from December 31, 2021 to June 30, 2023. In spite of the delay, the OCC, The Federal Reserve Board, and the FDIC issued a joint statement that encouraged institutions to cease entering into new contracts that use the USD LIBOR as a reference rate as soon …
What is the current status of the sunset of the LIBOR? Read More »
Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the …
HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption? Read More »
If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly …
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 …
Adverse Action Notice Requirements For Loans and Deposits Read More »
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 …
LIBOR – CFPB Proposes Amendments to Reg Z to Facilitate Transition Read More »
It’s more than just saying “No” When are adverse action notices required? Adverse action notices requirements for denied deposit accounts Adverse action notice requirements for commercial customers Notice of incompleteness requirements How should files be documented when a customer withdraws an application. What’s the difference between a withdrawn application and an application which was approved …
Servicing Compliance Webinar Series: Adverse Action Requirements Read More »
The financing of manufactured homes is a niche market. Not all banks offer this type of financing because of the varying underwriting requirements, risk and limited salability of this type of loan. As a bank begins to investigate manufacturing home lending, it is often focused on prudent underwriting and the safety and soundness for this …
TCA published Part 1 on August 23, 2018 describing managing HMDA risk amid reporting uncertainty. Shortly thereafter, the CFPB published additional guidance on August 31, 2018, as noted the same day as our Special Release. Due to the HMDA ambiguity and uncertainty, TCA is committed to providing bankers with A Better Way to decipher various …
The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …
HMDA Reporting Requirements: Business Purpose Loans Read More »
On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is …
New Rule for Using Closing Disclosure When Resetting Tolerances Read More »
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