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BAT CHAT

What do CDD and EDD Mean? Part I: Customer Due Diligence

By | November 8, 2018

What is all the buzz about customer due diligence (CDD) and enhanced due diligence (EDD)? The expectations for CDD and EDD did not change with the addition of the 5th BSA pillar. The expected due diligence requirements were simply codified. TCA® first addressed this topic in depth in a 2015 article. What does that mean […]

disclosure definition

FFIEC Releases 2017 CRA Public Data Tables

By | October 26, 2018

On October 25, 2018, the FFIEC released the public disclosures for CRA data submitted for the calendar year 2017. Institutions that report CRA data should go to the FFIEC website and download their disclosure tables for availability on request. The report should be made a part of your CRA Public File within three business days […]

FDIC sign

Regulatory Announcements October 2018

By | October 25, 2018

Various regulatory agencies have released resources over the past couple weeks. As part of being a compliance partner and showing clients A Better Way with TCA, please see the following key insights. Appraisal FAQ Released On October 16, 2018, the OCC, FDIC and FRB released a joint Frequently Asked Questions document in response to comments […]

selecting audit button

TRID is all grown up – now what? TRID Exams Get Tougher

By | October 17, 2018

Happy Birthday, TRID! It’s hard to believe but the TILA/RESPA Integrated Disclosure Rule is three years old this October! Remember when it was a cute little Reg? No? I must confess, neither do I! From the onset of compliance in October 2015 to the publication of the final rule on July 7, 2017, TRID remains […]

registration stamp

SAFE Act MLO Registration Renewal Period Starts November 1 Finding Your MLO’s Registration Can be Tricky

By | October 15, 2018

The NMLS Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies will be able to complete their annual attestation that the company’s record is up to date, pay their NMLS processing […]

ach concept

ACH Activity: Are You Managing Your BSA Risk?

By | October 11, 2018

The Bank Secrecy Act requires banks to manage risks associated with automated clearinghouse (ACH) and international ACH transactions (IAT), which results in a need for effective risk mitigation strategies and monitoring processes. The sheer volume of ACH activity makes the task seem impossible. TCA’s BSA Action Team (BAT) can help evaluate the effectiveness of a […]

compliance on laptop screen

The New Compliance Audit Expectation

By | September 27, 2018

Bankers have had whiplash over the last five years with new regulations, delayed regulations, regulatory relief and changes to new rules within one year from the initial effective date. Now on top of all of the changes, there are two more significant developments. First, compliance examinations have changed and consumer harm is the new hot […]

fair with wooden blocks

HMDA Part 3: Dropped MSA Codes Impact Fair Lending Review

By | September 20, 2018

Much has happened since the beginning of 2018, especially in the world of HMDA. This is Part 3 in TCA’s series of HMDA articles. Part 1 focused on managing HMDA risk amid reporting uncertainty and Part 2 focused on HMDA reporting for purchased loans. One HMDA data collection change that has surfaced is causing headaches […]

BAT CHAT

Quality Assurance Monitoring for BSA/AML Compliance Programs

By | September 14, 2018

When your institution is examined for compliance with any law or regulation, the measure of your efforts will be based on your ability to self-identify and self-correct any deficiencies. Ongoing monitoring of key processes helps to ensure that any errors or warning flags are identified early. Monitoring is a required element of a compliance management […]

safety deposit box

FinCEN Finalizes Beneficial Ownership Relief for Certain Accounts

By | September 10, 2018

he exceptive relief for CD renewals, loan renewals and modifications, and safe deposit box renewals has been made permanent. The industry has challenged FinCEN for some time with the operational challenges of obtaining beneficial ownership certifications for these auto‐renewing products. FinCEN finalized this exceptive relief by making it permanent on September 7, 2018 in FIN‐2018‐R003. […]

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