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Considerations for Managing an Offsite Review

By | April 6, 2020

They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the […]

virus, pathogen, infection

COVID-19 Business Impact: What Can You Do to Help?

By | March 23, 2020

Today’s complex world just got a whole lot more complex with the spread of COVID-19. There are new cases daily, stores have limited hours or are closing, restaurants are restricted to carry-out, schools are closed, and many of you have decided to close your lobbies and service your customers through the drive-through or walk-up windows. […]

compliance icon

CFPB Releases Two Policy Statements

By | March 17, 2020

In case you missed the CFPB announcements, the Bureau released two Policy Statements earlier this year. One statement addressed the prohibition on Abusive acts or practices and another notice described a new designation for some Bureau guidance, known as “Compliance Aids,” used to explain the legal status and role of guidance with that designation. Compliance […]

senior man holding money

Bank Secrecy Act: This Time, It’s Personal!

By | March 12, 2020

The headline reads more like the title of an action and adventure movie, but professionals who manage the day-to-day compliance with the Bank Secrecy Act know first-hand how much of an adventure their career path can take. As part of our annual BSA training, we often remind staff that the BSA carries both civil and […]

money, finance, wealth

Important CTR Update – Compliance Date Moves From February 1, 2020 to September 1, 2020

By | February 4, 2020

TCA’s January 21, 2020 “CTR 101 Webinar” highlighted one key change to the FinCEN CTR report – the evolving expectations on how to complete Part I Item 2. The original October 1, 2019 Notice published required a February 1, 2020 compliance date. The January 17, 2020 Notice extends the compliance date for files to September […]

loan agreement

Loan Documentation Chart

By | January 27, 2020

We’ve been told that TCA’s Loan Documentation Chart is a popular tool that provides lenders a ready reference guide helping them ensure borrowers are given the right disclosures on a timely basis. Many of our clients have laminated the Chart and provided it to loan officers and processors to assist with loan documentation tasks. Keep […]

bank photo

CRA Thresholds Announced for 2020

By | December 31, 2019

The annual CRA asset-size thresholds for covered financial institutions were announced on December 30, 2019 applicable for 2020. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. As a result of the 1.62% increase in the CPI, the […]

home mortgage application

HMDA and HPML Thresholds Bumped Up for 2020

By | December 20, 2019

The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations and credit unions. Like the CRA thresholds, the adjustments are due to the annual percentage increase in the Consumer Price Index for Urban Wage […]

hemp business

FinCEN Issues Guidance on Providing Financial Services to Hemp-Related Businesses

By | December 6, 2019

FinCEN and the regulators kicked off the holiday season by providing the industry with some clarification on the BSA implications of banking hemp-related businesses. In the News Release and Guidance, FinCEN said: “Because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act, banks are not required to file a Suspicious […]

security icon and privacy concept

314(a) and 314(b) Information Sharing: Is there a Difference?

By | November 14, 2019

The goal of my article is to help BSA staff have a clearer understanding of the differences between mandatory and voluntary information sharing. TCA’s BSA Action Team (BAT) wants to point out some key observations based on our BSA audits. In BSA, information requests are commonly referred to as sections 314(a) and 314(b) of the […]

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