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What do CDD and EDD Mean? Part II: Enhanced Due Diligence
The expectation for enhanced due diligence did not change with the passing of the 5th BSA pillar. However, examiner expectations for enhanced due diligence (EDD) continue to evolve because it is a critical component of your bank’s BSA Program. TCA® first addressed the EDD topic in a 2015 In Depth article. The November 2018 BAT […]
Maintaining the Legal Entity Identifier (LEI): Should Partially-exempt HMDA Filers Renew?
The passing into law of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) provided institutions with a partial exemption of some data fields under HMDA. One of the fields in the exemption is the Universal Loan Identifier (ULI) and allows institutions to report a Non-Universal Loan Identifier (NULI). The difference between the two […]
Fair Lending and Marketing in the Digital Age
There’s an old saying, “You don’t know what you don’t know” and that is certainly true when it comes to marketing initiatives meshing with the world of fair lending. The clash of both worlds and the often-divergent priorities have caused regulators to put this intersection under a microscope. A key fact today is that marketing […]
Defining Business Days for Lending
You must admit, defining what is a business day when it comes to lending regulations can be very confusing. Based on the questions we get from clients during our compliance reviews and through our compliance hotline, we find that lending staff is inconsistent and uncertain on how to count business days versus calendar days when […]
Financing Manufactured Homes Without Land
The financing of manufactured homes is a niche market. Not all banks offer this type of financing because of the varying underwriting requirements, risk and limited salability of this type of loan. As a bank begins to investigate manufacturing home lending, it is often focused on prudent underwriting and the safety and soundness for this […]
Accepting Private Flood Insurance Policy – Two Choices
TCA’s February 7, 2019 Special Release “Final Rules Released for Acceptance of Private Flood Insurance” said lenders can accept a private flood insurance policy and easily identify an acceptable policy. The rule suggests private providers add the following “compliance aid” clause: ‘‘This policy meets the definition of private flood insurance contained in 42 U.S.C. 4012a(b)(7) […]
CRA Public File Is No April Fools’ Joke!
April 1st is known as April Fools’ day, a time to play tricks and pranks. Some historians have noted that April Fools’ Day dates to 1582. It is speculated that the start of the new year had moved to January 1st and people who were slow to get the news and/or continued celebrating the new […]
It’s a Sign! (That’s Been Removed)
On Monday, March 18, 2019, the FDIC joined the other prudential regulators in removing the requirement to make available the Annual Disclosure Statement required under 12 CFR 350, to simplify their regulation as the information is available through the FDIC’s website. The OCC and FRB had previously removed this requirement in 2017 and 1998, respectively. […]
Understanding REMA
A common acronym being discussed more and more in fair lending circles is REMA. The goal of this article is to establish a better understanding of what REMA is and how it can impact your bank. REMA is defined as the Reasonable Expected Market Area, which is the geographical area the regulatory agency believes a […]
2019 Regulation E Claim Calendar
These days, losses from Regulation E error claims are accepted by many institutions as the cost of doing business. Many institutions are relying more heavily upon internal and/or third-party fraud detection and prevention resources. But as you know, managing risk of loss is just part of the story. Regulation E compliance and financial risk continues […]
