In Depth

mortgage application

Clarifying the Joint Intent Requirements at Application

Joint intent exceptions are a common finding in our compliance reviews. We have found that there are misconceptions on what constitutes joint intent and how it should be documented; most of the questions come from commercial versus consumer mortgage loan officers. Many of the questions we are asked include: Isn’t the joint financial statement enough

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loan agreement

Understanding REMA

A common acronym being discussed more and more in fair lending circles is REMA. The goal of this article is to establish a better understanding of what REMA is and how it can impact your bank. REMA is defined as the Reasonable Expected Market Area, which is the geographical area the regulatory agency believes a

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personal data

Amid Data Reporting Uncertainty, HMDA Risk Must Be Managed: Part 1—How is it Going?

Now that more than half the year is gone, many banks are starting to look more closely at their new 2018 HMDA LAR requirements because they have adequate volume to do testing. TCA wants to share with you what we have found in doing preliminary HMDA LAR validations. Many of the issues we’ve seen are

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fair with wooden blocks

The Expectation of Exceptions in the World of Fair Lending

Exception reporting is not new; all banks are required to report loan policy and loan documentation exceptions for Safety and Soundness. However, a new unwritten rule is fair lending exception tracking covering pricing and underwriting exceptions on consumer loan products. Whether it’s HMDA for banks with less than or more than 500 entries, regulators want

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