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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2025
On October 4, 2024, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections […]
Regulatory Updates – Third Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q3 2024. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. TCA – A Better Way!
1071 Preparation Guide | Article 7 1071 Brings New Mandates for Commercial Lending and Adverse Action Reporting
TCA often helps financial institutions review commercial loans for Regulation B compliance, which includes handling adverse action loan applications. During these reviews, TCA sees numerous mistakes, such as: TCA – A Better Way!
1071 Preparation Guide | Article 6 Gross Revenue – One of the Identifiers of Small Businesses
At TCA, we’ve already been fielding calls from clients confused about gross revenue under 1071. It is a key factor when identifying small business loans for the count of originations for the prior two years. Under 1071, a small business is defined as one with a gross revenue of $5 million or less. Financial institutions […]
1071 Preparation Guide | Article 5 What is an Application Date?
Application dates are sometimes a foreign concept in commercial lending. However, now that 1071 is a reality, commercial divisions everywhere will have asked themselves, “When do I have a completed application?” and perhaps the most important question of the day, “What will define my application date?” In commercial lending, it’s not as simple to determine […]
Back to School: Ready for Regulators’ Pop Quizzes?
With the summer winding down, the kids will be heading back to school and facing tests and the dreaded pop quizzes. But they are not the only ones. Compliance pros also must be ready for regulators’ tough questions. If your regulator were to give you a pop quiz, would you be ready? See if you […]
1071 Preparation Guide | Article 4 Identifying and Counting Covered Transactions
When implementing and creating processes for the 1071 Small Business LAR Rule, determining when the institution will be subject to the collection and reporting requirements is vital. The CFPB’s tiered implementation means we must first undertake a count to determine when the institution is subject to the collection and reporting of the covered data. The […]
1071 Preparation Guide | Article 3 Understanding the Flow of Commercial Lending
There is no doubt that the 1071 Small Business LAR Rule will change the way commercial lending departments operate. Compliance and Commercial Lending have not always gone hand in hand. Generally, there are lower compliance burdens for commercial purpose loans. As such, commercial lenders may be used to following strict guidelines and meeting regulatory requirements. […]
1071 Preparation Guide | Article 2 Identifying Stakeholders, Forming A Committee
Establishing a 1071 Implementation Committee is essential for your institution to ensure Regulation 1071 compliance. Your committee’s first order of business is preparing a risk assessment and reviewing the regulation to determine its impact on your processes and procedures. It also manages the project, prepares progress reports for stakeholders, addresses problems like delays and lack […]
1071 Preparation Guide – Article 1 Getting Started and Best Practices
We all knew more guidance on 1071 Dodd-Frank on Small Business Data Collection was coming. On May 17, 2024, the Consumer Financial Protection Bureau (CFPB) announced an interim final rule extending the compliance dates for data collection and data reporting for financial institutions. The Rule requires financial institutions to collect and report small business lending […]
