Throughout this pandemic, TCA Compliance has looked to the Centers for Disease Control and Prevention (CDC) for guidance on how best to manage the effects of COVID-19 on our business. As many states, including Illinois, are entering into Phase 5 of their COVID strategies (i.e. are re-opening), we have continued to look to the CDC […]
Covid-19 and Compliance Engagements – Update Read More »
On June 17, 2021, the U.S. got its first new National Holiday in 38 years. June 19th has been designated as “Juneteenth National Independence Day.” Our last new National Holiday, Martin Luther King, Jr. Day, the third Monday in January, was instituted in 1983. So, what’s different about these holidays and why does it affect
A New Federal Holiday. What Now? Read More »
For those of you regulated by the OCC and trying to plan the implementation of the June 2020 final CRA rule – Look Out! In OCC Bulletin 2021-24, issued May 18, 2021, the OCC stated that it will “Reconsider” the CRA Final Rule. Yes, you read that correctly. As many financial institutions and software vendors
OCC’s CRA June 2020 Final Rule – Maybe Read More »
Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the
HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption? Read More »
On February 17, 2021, the CFPB published a final rule to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The final rule also removed
CFPB Issues Changes to Rule on Higher-Priced Mortgage Loan Escrow Exemption Read More »
The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price Index for Urban Wage
HMDA and HPML Thresholds Bumped Up for 2021 Read More »
The annual CRA asset-size thresholds for covered financial institutions were announced December 17, 2020 applicable for 2021. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. As a result of the 1.29% increase in the CPI, the levels
CRA Asset-size Thresholds Announced for 2021 Read More »
On December 14, 2020, the FFIEC released the public disclosures for CRA data submitted for calendar year 2019. Note: If your institution does not report CRA small business, small farm or community development lending data, then this Special Release would not apply to you. Even if your institution is not a CRA reporter, a review
FFIEC Releases 2019 CRA Public Data Tables Read More »
If your institution is regulated by the FDIC or FRB, you can stop reading here, unless you want to see what could be coming your way in the near future. The OCC published a final Community Reinvestment Act rule on June 5, 2020 which marks a departure from the OCC, FDIC and FRB being “in
OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet? Read More »
The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M, which are tied to the Consumer Price Index. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators have released the new index
HPML Appraisal & Regulation Z and Regulation M Exemption Amounts Hold Steady for 2021 Read More »
We’re here to review your current compliance strategy and help you find A Better Way to manage risk.
