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Effective April 19, 2018, the Successors in Interest provisions will go into effect under RESPA. It is critical that institutions have procedures developed to address potential and verified Successors in Interest, as well as train appropriate staff as to the requirements under the Regulation. Part 3 of 3 focuses on this provision; refer to Part […]

April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear:

In eight days, the new 5th pillar – that includes Beneficial Ownership – takes effect. Starting May 11, 2018, Customer Due Diligence (CDD) will be added to the other four Bank Secrecy Act pillars. Right now, one of the most frequently discussed questions continues to be CD and loan renewals. TCA’s BSA Action Team (BAT)

The Community Reinvestment Act (CRA) celebrated its 40th anniversary in 2017. The Act was established to ensure banks were meeting the credit needs of the community they designated as their assessment or market area, which often was a circle around their branches. Passing a CRA exam was less troublesome since bankers only had to be

We have received numerous questions about how to report multiple properties on the HMDA LAR for 2018. Quite frankly, it can be very confusing because some fields are reported on the property securing the loan and other fields are reported on the transaction. The commentary for §1003.4(a)(9) – 2 states the following: MULTIPLE PROPERTIES WITH

You may think the subject of regulatory relief is not a popular one here at TCA. However, even a firm which specializes in providing solutions to manage regulatory compliance risk understands the importance of commonsense regulations, especially for community banks. We watch the legislative agenda carefully for indicators of change, but if I had a

Retail bankers have to confront a robust stock market, aggressive deposit acquisition strategies from growing firms, and maybe more than three Fed rate increases coming in 2018. Increasingly more creative methods are being used to attract deposit dollars. One such method is offering higher introductory rate products to catch attention while still holding down the

On August 30, 2017, FinCEN issued a memorandum titled “Memorandum on Financial Institution and Law Enforcement Efforts to Combat Elder Financial Exploitation.” Elder Financial Exploitation is the improper use of an older person’s funds or assets. Assets can also include the older person’s property or belongings. When an older person is being exploited, it often

It’s not atmospheric, but the term is banner‐like: sky-borne and all powerful. Before we can discuss the hot topic of shared multi-tenant environment risk in our next article, we need to take a step back and address, “What is Cloud Computing?” Sure, the cloud is out there, somewhere in the unknown, or most likely hidden

The long-awaited deadline to begin collecting 2018 HMDA data is here! Banking agencies have issued HMDA guidelines on data testing and additional information on HMDA data collection. Also, the Consumer Financial Protection Bureau (CFPB) has clarified some interpretations as it has worked through numerous questions via phone calls and emails from filers. One of the