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CRA Asset-size Thresholds Announced for 2024
The annual CRA asset-size thresholds for covered financial institutions were announced by the FDIC and Federal Reserve on December 20, 2023 and by the OCC on December 26, 2023 applicable for 2024. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to […]
Regulatory Updates – Fourth Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q4. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here. As always, TCA is here to help with A Better Way to answer all […]
TCA’s Top Five Client Lending Compliance Findings
As we approach the end of 2023, we wanted to take some time to reflect and comment on some of the most common lending missteps we’ve seen while performing audits for Clients during the year. TCA’s Top Five are firmly rooted in two regulations that examiners spend much time and focus on. Regulation Z and […]
New CRA Provisions Effective as of April 1, 2024
2024 is right around the corner and there are a few provisions everyone needs to keep on their agenda to ensure compliance with the new CRA rules finalized on October 24, 2023. In an effort to help clarify the new rules, TCA reached out to the FDIC in Washington DC. The result of this call […]
HMDA and HPML Thresholds Bumped Up for 2024
On December 18, 2023, 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 pegged to the annual percentage increase in the Consumer Price […]
HOEPA Calculation Worksheet for 2024 Loans
Tool to calculate whether your loan transaction is subject to HOEPA based on the points and fees and prepayment penalties paid by the borrower. Worksheets are updated annually to reflect changes loan amount thresholds. Select the worksheet based on the year the loan has been originated. Example: loan originated in December 2023 – select the HOEPA Calculation Worksheet 2023.01.
HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024
On November 13, 2023, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections […]
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 3 of a 3 Part Series In our last article we recapped items necessary to comply with the Ability-to-Repay (ATR) and Qualified Mortgage (QM) requirements when underwriting the loan. Compliance with Regulation Z does not stop at origination. This article recaps the servicing requirements for ARM loans. Loan Servicing and The Bank’s Core System […]
Deployment of Servicemembers
Due to recent events overseas, there has been recent deployment of US troops with potential additional deployment to happen in the future. Interest rates are higher than they have been in the past; the current Prime Rate is at 8.5%. All financial institutions should be prepared for Servicemembers enacting their rights under the Servicemembers Civil […]
Corporate Transparency Act Implementation
FinCEN has published a flurry of Beneficial Ownership information in the last two weeks which has led many financial institutions to question how any of this information applies to them, and how their account opening processes will be affected by the new rule going into effect on January 1, 2024. The good news for financial […]
