They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the […]
We’ve been told that TCA’s Loan Documentation Chart is a popular tool that provides lenders a ready reference guide helping them ensure borrowers are given the right disclosures on a timely basis. Many of our clients have laminated the Chart and provided it to loan officers and processors to assist with loan documentation tasks. Keep
The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds, which are tied to the Consumer Price Index, for Regulation Z and Regulation M exemptions. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators have released the new
On the eve of National Compliance Officer Day (and ironically when TCA published a discussion on banking industrial hemp), the United States House of Representatives passes H.R.1595 Safe Banking Act of 2019 which, if signed into law, would protect financial institutions from examiner criticism for providing banking services to cannabis-related businesses. The bill provides for
he exceptive relief for CD renewals, loan renewals and modifications, and safe deposit box renewals has been made permanent. The industry has challenged FinCEN for some time with the operational challenges of obtaining beneficial ownership certifications for these auto‐renewing products. FinCEN finalized this exceptive relief by making it permanent on September 7, 2018 in FIN‐2018‐R003.
Effective April 19, 2018, the Successors in Interest provisions will go into effect under RESPA. It is critical that institutions have procedures developed to address potential and verified Successors in Interest, as well as train appropriate staff as to the requirements under the Regulation. Part 3 of 3 focuses on this provision; refer to Part
Most of the provisions of the final 2016 Mortgage Servicing Rules took effect on October 19, 2017, with the remaining provisions effective April 19, 2018. In Part 1 of this series, we focused on the Definition of Delinquency, Requests for Information, Force‐Placed Insurance, Prompt Payment and Crediting, and the Small Servicer Determination. Part 2 of
An old scam targeting financing institutions is gaining new traction as data breaches become increasingly common and more information is freely available via social media. Banks are reporting increased occurrences of fraud targeting home equity lines of credit (HELOCs). Using a spoofed caller ID, a hacked email account or a faxed request, the fraudster requests