Uncategorized

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 […]

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

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

TCA has received questions from several clients recently regarding privacy notices and opt-out requirements, so we felt it was time to provide a refresher. Questions on whether written agreements meet the requirements for joint marketing arrangements should be referred to legal counsel. What information is covered? The GLB Privacy Rule protects a consumer’s “nonpublic personal

Since the economic upturn, HELOCs are quite popular because real estate values have gone up and rates are low. At a recent compliance meeting, a panel of Regulators discussed common findings or violations from recent examinations. Near the top of the list were HELOC statement violations. TCA findings agree with the examiner comments related to

The Consumer Financial Protection Bureau (CFPB) mandated changes to the collection of HMDA dataset information which was implemented in 2018. Significant changes were made in the areas of Ethnicity and Race which impacts the fair lending analysis process. In 2018 and going forward, Ethnicity and Race require additional information be available on the dataset form

We’ve been told that TCA’s Loan Documentation Chart is a popular tool that provides lenders a ready reference guide helping them ensure borrowers are given the right disclosures on a timely basis. Many of our clients have laminated the Chart and provided it to loan officers and processors to assist with loan documentation tasks. Keep

The goal of my article is to help BSA staff have a clearer understanding of the differences between mandatory and voluntary information sharing. TCA’s BSA Action Team (BAT) wants to point out some key observations based on our BSA audits. In BSA, information requests are commonly referred to as sections 314(a) and 314(b) of the

Regardless of bank size, complexity or risk profile, there is a universal myth when it comes to Fair Lending that there has been less enforcement since 2016. The truth is that Fair lending is one of the top enforcement rules. TCA recently attended a Fair Lending conference that included a regulatory panel discussion focusing on

We’ve received a lot of inquiries on what happened with the 2019 MSA codes: When will the pending 2019 demographic information changes be released? Has the 2018 HMDA Aggregate Data been announced? This “Special Delivery” will provide the most current information available to these questions. New MSA Codes Confusion In April 2018, OMB Bulletin No.