Compliance IQ

adjustable rate mortgage

“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls

Part 2 of a 3 Part Series In our last article, TCA recapped items necessary for origination and proper disclosure of ARM Loans. In this second article, we will review the requirements for complying with underwriting requirements unique to Adjustable-Rate Mortgages. Underwriting ARM Loans While banks are required to comply with the Ability-to-Repay standards in […]

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adjustable rate mortgage

“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls

Part 1 of a 3 Part Series For many years, we have experienced a low interest rate environment and originated predominantly fixed rate mortgages. Well times are changing – with the increase in interest rates, the popularity of Adjustable-Rate Mortgages is gaining momentum. We might be a little “rusty” in the process of originating and

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overdraft image with charts

FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion

The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating

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hdma

Do you Remember? HMDA – Reporting Open-End Lines of Credit

It’s time for a trip into the Way-Back Machine, all the way back to April 16, 2020, when the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C. This amendment permanently raised the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years. The

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Renewed Focus on Overdraft and “Junk” fees

One of the consequences of shrinking interest rates and interest margins is that financial institutions’ reliance on non-interest income has significantly increased over the last decade. The Consumer Financial Protection Bureau (CFPB) published an initiative on January 26, 2022 stating its intention to research the impact of fees on American consumers. The press release specifically

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B Prepared for Compliance in Commercial Lending

It’s common for many lenders to believe that commercial lending is exempt from federal compliance regulations. However, this would be untrue – commercial loans are subject to the following compliance regulations: Regulation C/HMDA, Flood Disaster Protection Act, and Regulation B/ECOA. This article will focus on only one the regulations above – Regulation B. Under this

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