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Have you updated your Illinois Community Reinvestment Act Lobby and Website Notice?
If you are a federally chartered institution or a state-chartered institution in any state OTHER than Illinois, you can stop reading here unless you are interested. Like some other states, Illinois passed their own Community Reinvestment Act statute in March of 2021 which can be found at 205 ILCS 735. Part of that law requires […]
Updates to Updates to the FDIC Official Signage Rule and Q&A
The FDIC delayed the implementation date for the updates to 12 CFR 328.4 (Signs for automated teller machines and like devices) and 328.5 (Signs for digital deposit-taking channels) which were originally to go into effect as of January 1, 2025, and postponed to May 1, 2025. The new mandatory compliance date is March 1, 2026. […]
New HMDA Filing Login Requirements
If you are a HMDA filer, CFPB has made the filing process more secure or more complicated depending on your viewpoint. According to this quick reference guide, effective January 1, 2025 a Login.gov login, which includes multifactor authentication (MFA), will be required to file your institution’s 2024 HMDA data. Users will no longer have the […]
Regulatory Updates – Fourth Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q4 2024. 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 […]
Time to Make New Year’s AML/CFT Resolutions
While many of us will be making personal resolutions for the New Year for personal self-improvement goals, AML/CFT Officers should consider a few resolutions that are geared towards their AML/CFT Programs. Policy and Procedure updates The Board of Directors annual approvals of policies are an important governance process. But when was the last time a […]
HMDA and HPML Thresholds Bumped Up for 2025
On December 27, 2024 the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and on December 23, 2024 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 increases or decreases in the […]
CRA Asset-size Thresholds Announced for 2025
The annual CRA asset-size thresholds for covered financial institutions were announced by the FDIC and Federal Reserve on December 19, 2024 and by the OCC on December 23, 2024 applicable for 2025. The cutoff adjustments are based on the change in the CPI-W (Consumer Price Index) for each 12-month period ending in November, rounded to […]
HOEPA Calculation Worksheet for 2025 Loans
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.
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Are there any requirements for specific disclosures on periodic home equity loan statements for consumers in bankruptcy? 12 CFR Part 1026.41 (Regulation Z) has requirements for closed-end consumer credit transactions but unclear about HELOCs.
Our review of Reg Z for open-end credit periodic statement requirements (1026.7) found nothing specific noted relating to loans in bankruptcy. The requirements only apply to closed-end credit under 1026.41. However, there may be state specific rules regarding statements and borrowers in bankruptcy. We recommend reaching out to your legal counsel or state banking association […]
The FDIC logo change was pushed until May 1, 2025, but my institution was wondering if the logo on our printed rate sheets given to customers upon request needs to be updated. My understanding is that the gold/black signs we have at the teller windows, and banker desks are NOT changing, and I think printed logos aren’t changing, but really, it’s mainly about the digital channels – and those need to be navy blue and black. So, if I’m correct, then the rate sheets do not require updates?
You are correct. Nothing pertaining to advertising is changing. The FDIC advertising rules stay the same. The gold/black signage, use of Member FDIC/FDIC-Insured that is all the same. So, on rate sheets, printed advertisements, social media, etc. there is no change. Lobby signage is an optional change. There is a provision to remove the signage […]
