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Do These Activities Qualify for CRA Credits?
COVID-19 has caused nationwide turmoil, including in the financial services industry. Banks have been flooded with inquiries regarding deferral of payments, modification of loan provisions and loan requests to keep businesses afloat. Many banks have asked TCA whether certain activities would be considered as CRA credits or qualified community development activities. The first of many […]
Preparing a Bank Secrecy Act Risk Assessment
Welcome to TCA’s BSA Back to Basics article series! Each month, our BSA experts will explore a section of the FFIEC BSA/AML Exam Manual, analyze the regulatory requirements, and offer insights to common findings in exams and audits. We will share best practices to help your BSA program continue to evolve. The first section of […]
UPDATE: Unlimited Savings Withdrawals Are a Reality
Ever since I’ve been in banking, Congress was going to relax the six-transaction limitation from savings and money market accounts. We won’t talk about how long that’s been, but it’s been a while. All it took was a global pandemic. Bankers and consumers have gotten their wish. (Actually, the FRB has been looking at this […]
Big Increase to Foreign Remittance Transfer Threshold
The CFPB released a Regulation E Update regarding remittance transfers and increasing the safe harbor threshold from 100 to 500 transactions per calendar year, effective July 21, 2020. Regulation E requires remittance transfer providers to provide customers with certain disclosures and establishes cancellation and error resolution procedures for these foreign transactions. Also, the update memorialized […]
Privacy Notice Opt-Out Requirements
TCA has received questions from several clients recently regarding privacy notices and opt-out requirements, so we felt it was time to provide a refresher. Questions on whether written agreements meet the requirements for joint marketing arrangements should be referred to legal counsel. What information is covered? The GLB Privacy Rule protects a consumer’s “nonpublic personal […]
CFPB Waives TRID and Rescission Timeframes
On April 29, 2020, the Consumer Financial Protection Bureau released an interpretive ruling effective on May 4, 2020 providing rescission relief. If a consumer refinances or applies for a mortgage loan and needs funds due to the COVID-19 pandemic before the end of the waiting periods, lenders can waive and modify the waiting period for […]
APRWin and APYWin Replaced with Web Versions
It’s the end of an era. I have been in audit or compliance for {shudder} over 30 years now, and in all that time have had APRWin as a constant companion to test the validity of those APRs. It’s like an old friend. The current version has been around since May 2008. APYWin isn’t quite […]
HMDA Reporting Threshold Changes for 2020 and Beyond
On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. To assist with understanding the transition, the Bureau has published new resources and updated some existing ones: Unofficial, informal redline to reflect changes to Regulation C Executive Summary HMDA Rule Key Dates Timeline 2020-2022 HMDA institutional coverage chart, effective […]
Agencies Release Interim Final Rule on Deferral of Appraisals/Evaluations
On April 14, 2020 the OCC, FRB and FDIC issued an interim final rule effective April 17, 2020 until December 31, 2020 (comments due June 1, 2020) which will amend the agencies’ regulations requiring appraisals of real estate for certain transactions. (NOTE: This rule was finalized on October 16, 2020.) Under the interim final rule, […]
