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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 […]
Tips for a Successful Offsite Review
The saying goes that the only constant is change, which is true. In this post-pandemic environment, TCA continues to complete most engagements remotely. Technology advancements have made the process easier, but offsite engagements create different challenges. Please take a moment to review some tips for an efficient, effective TCA remote review. Ensuring a Successful Remote […]
Mitigate Risk: Understand Your Lending Patterns
Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan […]
Regulatory Updates – First Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q1 2024. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here. As always, TCA is here to help with A Better Way to answer […]
AML/CFT Transaction Monitoring – Importance of Tuning Your AMS Model
Regulators expect compliance with the standards established in the model risk management guidance (MRMG) (Federal Reserve SR Letter 11-7, OCC Bulletin 2011-12; FDIC FIL 22-2017) as well as the April 9, 2021, Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance. This guidance relates to systems or models used […]
TCA’s Top 5 BSA/AML Concerns
The Bank Secrecy Act/Anti-Money Laundering area of compliance is always evolving. As an example, we are currently transitioning the name of this specialized area of compliance from Bank Secrecy Act (BSA) to Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) to coincide with the term’s examiners are now using within their documents and reports. […]
2024 RCM Hotline Helpful Tips
As we continue to move forward into 2024, we wanted to take the time to share some tips regarding our Regulatory Compliance Manager (RCM) hotline and article accessibility. We want to ensure that all of our RCM clients have the best experience possible regarding these services. Tip #1: Please email all hotline questions to [email protected]. […]
Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help […]
TCAs Client Top Five Deposit Missteps
Although there have been few new or changed regulations related to Deposit Compliance, missteps in compliance with these regulations can cause consumer harm. It’s important to stay focused and make sure staff changes or the implementation of new systems don’t increase errors at your institution. Helping institutions identify errors in deposit operations is a routine […]
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 […]
