Turning Downtime Into Uptime: Using Regulatory Lulls to Fortify Compliance
The Critical Role of Compliance Management System Risk Assessment We are all familiar with the emphasis placed on meaningful risk assessments throughout our industry. Among the many risk assessments that should be created for banks, the Compliance Management Systems Risk Assessment (CMSRA) is perhaps the most important. The importance of a thorough Risk Assessment cannot
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For the purposes of Regulation E Error Resolution Claims, when is the provisional credit due?
The Institution must grant provisional credit to the consumer within 10 business days after the Institution has been informed of an unauthorized transaction on the account. Provisional credit also does not have to be provided unless the notice of error has been provided in writing (i.e. not oral). This does not mean investigation doesn’t start
Can a financial institution have all borrowers waive the Appraisal Delivery or is there special circumstances required to waive the Appraisal Delivery timing requirements?
Answer: A customer may waive delivery of an appraisal without a reason as long as the waiver is collected at least 3 business days prior to consummation or account opening. The Institution is permitted to offer every customer the opportunity to waive the delivery of the Appraisal and then follow what the customer decides. The
1071 Preparation Guide | Article 4 Identifying and Counting Covered Transactions
When implementing and creating processes for the 1071 Small Business LAR Rule, determining when the institution will be subject to the collection and reporting requirements is vital. The CFPB’s tiered implementation means we must first undertake a count to determine when the institution is subject to the collection and reporting of the covered data. The
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1071 Preparation Guide | Article 3 Understanding the Flow of Commercial Lending
There is no doubt that the 1071 Small Business LAR Rule will change the way commercial lending departments operate. Compliance and Commercial Lending have not always gone hand in hand. Generally, there are lower compliance burdens for commercial purpose loans. As such, commercial lenders may be used to following strict guidelines and meeting regulatory requirements.
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The Anticipation is Over! Small Business LAR Final Rule Released
It’s here! The much anticipated and long awaited final Small Business LAR rule has been released! Rest assured TCA’s Small Business LAR Action Team (SBLAT) is on it. We’re working through the Final Rule to help you implement the new policies and procedures necessary to comply with the rule. Look for more articles from TCA
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