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Our database of articles starts in 2018. If there’s an older article you need or there’s a subject that you’d like to research, please call 800-934-REGS or email us [email protected] and we’ll get the information to you.

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HUD Issues Revised SCRA Notice

By | April 2, 2018

Thanks to an eagle‐eyed client for sharing with us a best‐kept secret that HUD released an updated SCRA Notice. As you know, the old form expired in December 2017. From what we can tell, the only changes to the notice are dates and the reference to 50 USC 3901‐4403, which was changed from the former …

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corporate social responsibility

CRA Celebrated its 40th Year—Look for Greater Emphasis on Community Development Efforts

By | March 28, 2018

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 …

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CFPB Issues Updated Prepaid Card Compliance Guide

By | March 20, 2018

On March 13, 2018, the CFPB issued an updated Small Entity Compliance Guide (SEG) to incorporate recent 2018 changes to the Regulation E Prepaid Card rules which take effect on April 1, 2019. The Bureau released guidance for completing the short‐form disclosure for prepaid accounts, which includes not only a line‐by‐line how‐to but specifics on …

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HMDA Reporting for Loans Secured by Multiple Properties

By | March 16, 2018

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 …

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HMDA: Getting it Right Lives Again!

By | February 28, 2018

On February 21, 2018, the FFIEC released a revised HMDA: Getting It Right guide (GIR) for Regulation C changes which took effect on January 1, 2018. The GIR is in the same format as previous guides and it includes the regulation, appendices and commentary in 12 CFR §1002 plus the CFPB tools. The GIR is …

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suspicious activity report

Making SAR Narratives Error‐Proof

By , | February 22, 2018

Each SAR field is entered into FinCEN’s searchable database, so law enforcement can pull information or run inquires to aid investigations into financial and other illicit crimes. That’s why SARs are crucial. The law enforcement agencies are your audience and they need to know the whole “story” since they were not actively involved in the …

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changes ahead signs

Is Regulatory Relief Finally Happening?

By | February 20, 2018

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 …

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wall street

Avoid Regulation DD Pitfalls When Disclosing Introductory Rates

By | February 15, 2018

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 …

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FinCEN Finalizes New SAR

By | February 13, 2018

FinCEN announced updates to the Suspicious Activity Report (SAR) filing format in a notice to e‐filers. The announcement says that the revisions adhere to the changes listed in FinCEN’s February 2, 2017 Federal Register notice and will be live in June 2018. In these new filings, batch submissions will have to be made in an …

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senior man holding money

Combating Elder Financial Exploitation

By | February 8, 2018

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 …

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