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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 […]
COVID-19 Business Impact: What Can You Do to Help?
Today’s complex world just got a whole lot more complex with the spread of COVID-19. There are new cases daily, stores have limited hours or are closing, restaurants are restricted to carry-out, schools are closed, and many of you have decided to close your lobbies and service your customers through the drive-through or walk-up windows. […]
CFPB Releases Two Policy Statements
In case you missed the CFPB announcements, the Bureau released two Policy Statements earlier this year. One statement addressed the prohibition on Abusive acts or practices and another notice described a new designation for some Bureau guidance, known as “Compliance Aids,” used to explain the legal status and role of guidance with that designation. Compliance […]
Bank Secrecy Act: This Time, It’s Personal!
The headline reads more like the title of an action and adventure movie, but professionals who manage the day-to-day compliance with the Bank Secrecy Act know first-hand how much of an adventure their career path can take. As part of our annual BSA training, we often remind staff that the BSA carries both civil and […]
Important CTR Update – Compliance Date Moves From February 1, 2020 to September 1, 2020
TCA’s January 21, 2020 “CTR 101 Webinar” highlighted one key change to the FinCEN CTR report – the evolving expectations on how to complete Part I Item 2. The original October 1, 2019 Notice published required a February 1, 2020 compliance date. The January 17, 2020 Notice extends the compliance date for files to September […]
Loan Documentation Chart
We’ve been told that TCA’s Loan Documentation Chart is a popular tool that provides lenders a ready reference guide helping them ensure borrowers are given the right disclosures on a timely basis. Many of our clients have laminated the Chart and provided it to loan officers and processors to assist with loan documentation tasks. Keep […]
