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community reinvestment act

New CRA Provisions Effective as of April 1, 2024

By | December 22, 2023

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 […]

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HMDA and HPML Thresholds Bumped Up for 2024

By | December 19, 2023

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 […]

mortgage loan disclosure

HOEPA Calculation Worksheet for 2024 Loans

By | December 14, 2023

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.

HOEPA Calculation Worksheet for 2024 Loans Read More »

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2024

By | November 14, 2023

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 […]

adjustable rate mortgage

“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls

By | November 2, 2023

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

By | October 26, 2023

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 […]

new rules chalk on chalkboard

Corporate Transparency Act Implementation

By | October 24, 2023

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 […]

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Regulatory Updates – Third Quarter 2023

By | October 10, 2023

Below is a link to the Regulatory Updates as of the end of Q3. 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 […]


In a Government Shutdown the National Flood Insurance Program Could be Affected

By , | September 27, 2023

So, the Government may shut down. Again. This has happened before and will likely happen again. When this happens, one of the many “non-essential” services and programs is the National Flood Insurance Program (NFIP). So, what do we do if/when a shutdown happens? If there is a disruption to the NFIP, we should be prepared […]

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New Threshold Amounts for 2024 under Regulation Z CARD Act, HOEPA and QM Sections

By | September 21, 2023

Based on the 4.6% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2023, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2024. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 4.9% increase […]

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