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complaints folder

Core Principles: Consumer Complaints, an early warning detection system

Customer complaints – Two simple yet powerful words which should be drivers for action in every Financial Institution. Recently I attended and event by the Chicagoland Compliance Association where a panel that included representation from each Regulator spoke. One comment from the panel struck a chord as they spoke about customer complaints. This is a […]

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home mortgage application

HOEPA VS HPML (High-Cost and Higher Priced Mortgage Loan)

The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the Truth-in-Lending Act (TILA) to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees. Higher Priced Mortgage Loans (HPML) were implemented as part of the Mortgage Disclosure Improvement Act in 2009

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new rules chalk on chalkboard

FDIC Signage and Advertising – Things They Are A-Changin’

On December 20, 2023 the FDIC approved and issued a final rule regarding changes to 12 CFR 328: rules for the use of FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentations of Insured Status, and Misuse of the FDIC’s Name or Logo. The updated rules are effective April 1, 2024, with a mandatory compliance

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adjustable rate mortgage

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

Part 3 of a 3 Part Series In our last article we recapped items necessary to comply with the Ability-to-Repay (ATR) and Qualified Mortgage (QM) requirements when underwriting the loan. Compliance with Regulation Z does not stop at origination. This article recaps the servicing requirements for ARM loans. Loan Servicing and The Bank’s Core System

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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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