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Privacy Notice Opt-Out Requirements
TCA has received questions from several clients recently regarding privacy notices and opt-out requirements, so we felt it was time to provide a refresher. Questions on whether written agreements meet the requirements for joint marketing arrangements should be referred to legal counsel. What information is covered? The GLB Privacy Rule protects a consumer’s “nonpublic personal […]
CFPB Waives TRID and Rescission Timeframes
On April 29, 2020, the Consumer Financial Protection Bureau released an interpretive ruling effective on May 4, 2020 providing rescission relief. If a consumer refinances or applies for a mortgage loan and needs funds due to the COVID-19 pandemic before the end of the waiting periods, lenders can waive and modify the waiting period for […]
APRWin and APYWin Replaced with Web Versions
It’s the end of an era. I have been in audit or compliance for {shudder} over 30 years now, and in all that time have had APRWin as a constant companion to test the validity of those APRs. It’s like an old friend. The current version has been around since May 2008. APYWin isn’t quite […]
HMDA Reporting Threshold Changes for 2020 and Beyond
On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. To assist with understanding the transition, the Bureau has published new resources and updated some existing ones: Unofficial, informal redline to reflect changes to Regulation C Executive Summary HMDA Rule Key Dates Timeline 2020-2022 HMDA institutional coverage chart, effective […]
Agencies Release Interim Final Rule on Deferral of Appraisals/Evaluations
On April 14, 2020 the OCC, FRB and FDIC issued an interim final rule effective April 17, 2020 until December 31, 2020 (comments due June 1, 2020) which will amend the agencies’ regulations requiring appraisals of real estate for certain transactions. (NOTE: This rule was finalized on October 16, 2020.) Under the interim final rule, […]
BSA Compliance & COVID-19: FinCEN & SBA Updates
Over the past month, every facet of our lives has dramatically changed. Shelter-in-place orders, rotating bank staff, lobby closures, government stimulus programs and a myriad of regulatory updates have stretched risk management resources. TCA has received many questions from clients asking for our interpretation of guidance that has been issued in response to these regulatory […]
HELOC Statements – The Ever-Present Risk
Since the economic upturn, HELOCs are quite popular because real estate values have gone up and rates are low. At a recent compliance meeting, a panel of Regulators discussed common findings or violations from recent examinations. Near the top of the list were HELOC statement violations. TCA findings agree with the examiner comments related to […]
Uncovered Fair Lending Demographic Data Flaw
The Consumer Financial Protection Bureau (CFPB) mandated changes to the collection of HMDA dataset information which was implemented in 2018. Significant changes were made in the areas of Ethnicity and Race which impacts the fair lending analysis process. In 2018 and going forward, Ethnicity and Race require additional information be available on the dataset form […]
Considerations for Managing an Offsite Review
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 […]
