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In a Government Shutdown the National Flood Insurance Program Could be Affected
So, the Government may shut down. Again. This has happened before and will likely happen again. When this happens, one of the many “non-essential” services and programs is the National Flood Insurance Program (NFIP). So, what do we do if/when a shutdown happens? If there is a disruption to the NFIP, we should be prepared …
In a Government Shutdown the National Flood Insurance Program Could be Affected Read More »
New Threshold Amounts for 2024 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 4.6% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2023, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2024. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 4.9% increase …
New Threshold Amounts for 2024 under Regulation Z CARD Act, HOEPA and QM Sections Read More »
NCUA Updated Address for Adverse Actions
If you are not regulated by the NCUA then you can skip to the end of this Special Release. If you are regulated by the NCUA, then you need to know the CFPB amended some addresses in Regulation B, Regulation V and a website referencing Regulation Z APR Table. The August 25, 2023 Federal Register …
“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 …
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls Read More »
Monitoring Commitments
What flies like a bird and is something we never have enough of? Of course, it’s Time. You don’t need to look at a calendar to know we are more the done with half the year and summer is nearing its end; all you have to do is walk through your favorite store or watch …
Regulatory Updates – Second Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q2. 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 all …
“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 …
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls Read More »
1071 Small Business Loan Count Methodology
As we are all aware by now the Final Rule for the 1071 Small Business Data Collection was issued March 30, 2023. Many financial institutions are questioning where and how to start the process of identifying the small business loans to be counted. The final rule provides three methods to determine if a small business …
A New Federal Holiday and an Old Federal Holiday – Alleviate The Confusion
So, if this article looks familiar, that’s because we sent out a similar version in the past two years and there is still some confusion as some institutions are open and some are closed. On June 17, 2021, the US got its first national holiday in 38 years. June 19 has been designated as “Juneteenth …
A New Federal Holiday and an Old Federal Holiday – Alleviate The Confusion Read More »
FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion
The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating …
FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion Read More »
