What do we need to do with mail that is returned to the Bank?
What do we need to do with mail that is returned to the Bank? Read More »
On a loan where the borrower enacted their rights under SCRA, how is interest paid by the borrower refunded? Is it Interest from time the Institution was notified, or time Borrower was to report? Is it a refund of any interest to the borrower or can the institution decide?
Interest is refunded from the effective date to report for active duty. §3937 (b)(2) LIMITATION EFFECTIVE AS OF DATE OF ORDER TO ACTIVE DUTY- Upon receipt of written notice and a copy of orders calling a servicemember to military service, the creditor shall treat the debt in accordance with subsection (a), effective as of the
Does an institution have to pull a flood determination on multi-parcels which have the same PIN?
Answer: Since the property is being deeded over to the borrower, the borrower is essentially purchasing the property for what is remaining Yes. Although no new money is being advanced, this is a new HELOC that will allow a customer to redraw on funds from the line once the loan is paid down. The Right
Inflation-Adjusted Penalties. Scary!
Giant jack-o-lanterns, witches, and ghouls are starting to decorate our neighborhoods, and spooky stories are being told around the campfires. Don’t you love this time of year? Remember, frightening compliance stories can continue year-round. The number and size of fines financial institutions can be assessed for violating Regulations can be quite steep. Institutions of every
Inflation-Adjusted Penalties. Scary! Read More »
Back to School: Ready for Regulators’ Pop Quizzes?
With the summer winding down, the kids will be heading back to school and facing tests and the dreaded pop quizzes. But they are not the only ones. Compliance pros also must be ready for regulators’ tough questions. If your regulator were to give you a pop quiz, would you be ready? See if you
Back to School: Ready for Regulators’ Pop Quizzes? Read More »
HOEPA VS HPML (High-Cost and Higher Priced Mortgage Loan)
The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the Truth-in-Lending Act (TILA) to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees. Higher Priced Mortgage Loans (HPML) were implemented as part of the Mortgage Disclosure Improvement Act in 2009
HOEPA VS HPML (High-Cost and Higher Priced Mortgage Loan) Read More »
TCAs Client Top Five Deposit Missteps
Although there have been few new or changed regulations related to Deposit Compliance, missteps in compliance with these regulations can cause consumer harm. It’s important to stay focused and make sure staff changes or the implementation of new systems don’t increase errors at your institution. Helping institutions identify errors in deposit operations is a routine
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TCA’s Top Five Client Lending Compliance Findings
As we approach the end of 2023, we wanted to take some time to reflect and comment on some of the most common lending missteps we’ve seen while performing audits for Clients during the year. TCA’s Top Five are firmly rooted in two regulations that examiners spend much time and focus on. Regulation Z and
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A Loan Officer took an application by telephone, and the borrower failed to sign the acknowledgement to apply for joint credit on the application that was mailed for signature. How can joint intent be documented?
Answer: While it is always preferred that the borrower initial the joint intent statement on the application, there are times when the borrower fails to do so. Loan Officers should ask the borrowers this question during the initial phone application and document it in their notes. In the case where an application is returned without
CRA Public File Reminder
April 1st is known as April Fools’ day and a time to play tricks and pranks. But did you know on April 1, 1748, the Ruins of Pompeii were rediscovered by Spaniard Rocque Joaquin de Alcubierre? Guess it is time to rediscover the CRA Public File and make sure nothing ancient is inside! By now
CRA Public File Reminder Read More »
