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Beneficial Ownership and Lending: Have we considered all possibilities?

By | June 6, 2018

April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear: […]

cd rate

FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals

By | May 17, 2018

Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our […]

adjustable rate mortgage

Mortgage Servicing Rules Part 2 of 3

By | May 9, 2018

Most of the provisions of the final 2016 Mortgage Servicing Rules took effect on October 19, 2017, with the remaining provisions effective April 19, 2018. In Part 1 of this series, we focused on the Definition of Delinquency, Requests for Information, Force‐Placed Insurance, Prompt Payment and Crediting, and the Small Servicer Determination. Part 2 of […]

due diligence

CDD and Auto-Renewing Products: Are you BSA Compliant

By | May 3, 2018

In eight days, the new 5th pillar – that includes Beneficial Ownership – takes effect. Starting May 11, 2018, Customer Due Diligence (CDD) will be added to the other four Bank Secrecy Act pillars. Right now, one of the most frequently discussed questions continues to be CD and loan renewals. TCA’s BSA Action Team (BAT) […]

closing costs on paper

New Rule for Using Closing Disclosure When Resetting Tolerances

By | April 27, 2018

On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is […]

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FFIEC Joint Statement on Cyber Insurance

By | April 24, 2018

On April 10, 2018, the FFIEC issued a joint statement regarding Cyber Insurance and its role in Risk Management programs. With Cybersecurity events becoming commonplace, do you have the proper insurance to protect the bank and its assets? Although Cyber Insurance may be a part of the Risk Mitigation program, it is not the final […]

using bucket to collect water from leaking roof

April Showers Bring May Flowers: Are you compliant with Flood?

By | April 20, 2018

Spring has sprung! Well, in some places anyway. Let’s make sure you don’t spring a leak in your portfolio of flood loans. Here is a spring cleaning checklist of your flood program. In general, an institution under the OCC, FRB or FDIC rules shall not make, increase, renew or extend (MIRE) any designated loan unless […]

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What is the Cloud Part 2: Risk Appetite Discussion

By | April 11, 2018

The goal of my last article was to eliminate the mystery of the “Cloud” by breaking it into easy‐to‐understand building blocks. A key takeaway is that the cloud is not a single operating option; it has many building blocks. The blocks or choices have a significant impact on your bank’s risk exposure. To make it […]

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FinCEN Issues Highly Anticipated CDD Beneficial Ownership FAQs

By | April 3, 2018

On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018. The FAQ addresses the following topics, among others: Beneficial Ownership Threshold Interaction of the beneficial ownership threshold with other AML program obligations Collection of beneficial ownership information for direct […]

colorful houses

HUD Issues Revised SCRA Notice

By | April 2, 2018

Thanks to an eagle‐eyed client for sharing with us a best‐kept secret that HUD released an updated SCRA Notice. As you know, the old form expired in December 2017. From what we can tell, the only changes to the notice are dates and the reference to 50 USC 3901‐4403, which was changed from the former […]

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