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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.
Mortgage Servicing Rules – Successor in Interest Part 3 of 3
Effective April 19, 2018, the Successors in Interest provisions will go into effect under RESPA. It is critical that institutions have procedures developed to address potential and verified Successors in Interest, as well as train appropriate staff as to the requirements under the Regulation. Part 3 of 3 focuses on this provision; refer to Part …
Mortgage Servicing Rules – Successor in Interest Part 3 of 3 Read More »
HMDA Relief is Here for Many . . . Now What?
Last week the compliance and risk management worlds reacted with joy over the signing of Senate Bill S. 2155. For most bankers, the passing of this bill represented the most significant regulatory relief in decades. Of noted importance was the rollback of the expanded data collection rules for the Home Mortgage Disclosure Act (HMDA). However, …
Beneficial Ownership and Lending: Have we considered all possibilities?
April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear: …
Beneficial Ownership and Lending: Have we considered all possibilities? Read More »
FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals
Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our …
FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals Read More »
Mortgage Servicing Rules Part 2 of 3
Most of the provisions of the final 2016 Mortgage Servicing Rules took effect on October 19, 2017, with the remaining provisions effective April 19, 2018. In Part 1 of this series, we focused on the Definition of Delinquency, Requests for Information, Force‐Placed Insurance, Prompt Payment and Crediting, and the Small Servicer Determination. Part 2 of …
CDD and Auto-Renewing Products: Are you BSA Compliant
In eight days, the new 5th pillar – that includes Beneficial Ownership – takes effect. Starting May 11, 2018, Customer Due Diligence (CDD) will be added to the other four Bank Secrecy Act pillars. Right now, one of the most frequently discussed questions continues to be CD and loan renewals. TCA’s BSA Action Team (BAT) …
CDD and Auto-Renewing Products: Are you BSA Compliant Read More »
New Rule for Using Closing Disclosure When Resetting Tolerances
On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is …
New Rule for Using Closing Disclosure When Resetting Tolerances Read More »
FFIEC Joint Statement on Cyber Insurance
On April 10, 2018, the FFIEC issued a joint statement regarding Cyber Insurance and its role in Risk Management programs. With Cybersecurity events becoming commonplace, do you have the proper insurance to protect the bank and its assets? Although Cyber Insurance may be a part of the Risk Mitigation program, it is not the final …
April Showers Bring May Flowers: Are you compliant with Flood?
Spring has sprung! Well, in some places anyway. Let’s make sure you don’t spring a leak in your portfolio of flood loans. Here is a spring cleaning checklist of your flood program. In general, an institution under the OCC, FRB or FDIC rules shall not make, increase, renew or extend (MIRE) any designated loan unless …
April Showers Bring May Flowers: Are you compliant with Flood? Read More »
What is the Cloud Part 2: Risk Appetite Discussion
The goal of my last article was to eliminate the mystery of the “Cloud” by breaking it into easy‐to‐understand building blocks. A key takeaway is that the cloud is not a single operating option; it has many building blocks. The blocks or choices have a significant impact on your bank’s risk exposure. To make it …
What is the Cloud Part 2: Risk Appetite Discussion Read More »
