Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]
When the Tide is Against You 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
The Great Debate — Is This a Finance Charge? Read More »
“What are you doing to ensure diversity, equity and inclusion (DEI)?” That question routinely comes up during conference calls among us, clients, and regulatory agencies. Businesses, educational institutions, and non-profit organizations all are focusing on DEI. Financial institutions are no exception. In fact, regulatory agencies emphasize the importance of DEI in written communications about the Fair
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 »
The mortgage application, the 1003 or URLA – these are all synonyms for the standard residential mortgage application which has been changed. Navigating through these changes can be stressful; but we are here to help. Fannie/Freddie announced the release of the redesigned Uniform Residential Loan Application (URLA) on August 23, 2016. The changes would include
The Fannie Mae and Freddie Mac Application: New and Improved? Read More »
On April 16, 2020, The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds in Regulation C for financial institutions reporting data under the Home Mortgage Reporting Act (HMDA). A permanent threshold for collecting closed end mortgage reporting data went from 25 to 100 loans effective July 1, 2020. Also, open-end
No Longer A HMDA Reporter – Fair Lending Still Applies Read More »
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs,
Three Hot CRA Concerns Read More »
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 »
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