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TRID is all grown up – now what? TRID Exams Get Tougher
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 […]
SAFE Act MLO Registration Renewal Period Starts November 1 Finding Your MLO’s Registration Can be Tricky
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 Activity: Are You Managing Your BSA Risk?
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 […]
The New Compliance Audit Expectation
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 […]
HMDA Part 3: Dropped MSA Codes Impact Fair Lending Review
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 […]
Quality Assurance Monitoring for BSA/AML Compliance Programs
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 […]
FinCEN Finalizes Beneficial Ownership Relief for Certain Accounts
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. […]
HMDA Part 2: How to Report Purchased Loans
TCA published Part 1 on August 23, 2018 describing managing HMDA risk amid reporting uncertainty. Shortly thereafter, the CFPB published additional guidance on August 31, 2018, as noted the same day as our Special Release. Due to the HMDA ambiguity and uncertainty, TCA is committed to providing bankers with A Better Way to decipher various […]
CFPB Provides Guidance on Handling HMDA Changes
As we all well know, S.2155 provided some anticipated regulatory relief covering many areas. One of the relief items was HMDA relief, which TCA covered in a previous special release. As a quick refresher, the Act provides that an institution does not need to report data with respect to closed‐end mortgage loans if it originated […]
2019 Thresholds under Regulation Z’s CARD Act, HOEPA and QM Sections
Based on the Consumer Price Index in effect on June 1, 2018, which increased 2.5%, the Consumer Financial Protection Bureau (CFPB) released a number of new threshold amounts which go into effect on January 1, 2019. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged in […]
