Answer: Yes, financial institutions can decide to remain open on Juneteenth, the newest federal holiday. Many financial institutions remain open on other Federal holidays, such as Veteran’s Day, Martin Luther King Jr. Day, etc. to conduct business. Even though the institution may decide to remain open on Federal holidays, keep in mind that the business […]
Answer: Because the overall term of the C-P loan is greater than 12 months, you are required to escrow for flood insurance. The fact that the construction phase is 12 months or less is irrelevant. This means that you must require flood insurance at consummation.
Answer: The sunset of the LIBOR has been delayed from December 31, 2021 to June 30, 2023. In spite of the delay, the OCC, The Federal Reserve Board, and the FDIC issued a joint statement that encouraged institutions to cease entering into new contracts that use the USD LIBOR as a reference rate as soon
What is the current status of the sunset of the LIBOR? Read More »
Answer: Yes. The Financial Institution needs to be aware of what makes up the data that is obtained and how the data is applied. These algorithms may be filtered by zip codes, level of education or purchasing behaviors. The Financial Institution needs to ensure the algorithms used do not cause disparate impact by eliminating protected
Answer: TCA continues to see examiner scrutiny on alert resolution. When documenting a response to an alert, it does not need to be as in-depth as an investigation narrative; however, it must explain the who, what, where, when, why, and how. This creates continuity for other BSA staff, examiners, and auditors to understand how you
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