Overdraft Protection Program Review
Delivering Support that Mitigates Risk, Services Customers, and Protects Your Reputation
We provide knowledge, experience, and guidance that allow your bank to adhere to consumer protection laws and manage their complexities.
Consumer compliance professionals face a daunting task trying to stay up on the changing consumer compliance landscape and fully understanding the implications that every regulatory change has on your bank.
That's where we come in.
We've spent decades building our expertise in this complex and often conflicting area of compliance. That experience has given us a ringside seat on how banks find themselves in regulatory trouble.
Whatever your challenge, we've likely seen something similar, and we have the expertise to review all applicable federal consumer regulations, from Regulation B to Regulation Z.
Still, we know that each bank is unique.
That’s why we start each engagement by gaining a 360-degree view of your bank operations and culture before conducting any audits, reviews, and testing.
This initial process allows us to understand your unique risk, pinpoint areas of concern, and recommend an appropriate review scope. Our approach helps you mitigate your risk and prepare for your next regulatory exam.
We also enhance your compliance culture by providing sensible recommendations and best practices throughout the process to help you put corrective action in place.
After all, protecting and serving your customers are crucial to building your community's trust, maintaining your reputation, and strengthening your bank.
TCA provides A Better Way to manage your consumer compliance obligations.
Key Deliverables Include:
- Lending, Loan Origination, and Loan Servicing – Review practices, policies, and procedures to measure, control, and minimize lending-related consumer risk.
- Deposit-related regulations and statutes – Review practices, policies, and procedures to measure, control, and minimize deposit-related consumer risk.
- Home Mortgage Disclosure Act (HMDA) – Ensure the data reported on your loan application register (LAR) is accurate prior to the required filing date.
- Compliance Management System (CMS) – Ensure that your CMS reflects your current risk and meets regulatory expectations for board and management oversight, effective monitoring and audit schedules, and policies and procedures to mitigate consumer harm.
Consumer Compliance Insights
Regulators expect compliance with the standards established in the model risk management guidance (MRMG) (Federal Reserve SR Letter 11-7, OCC Bulletin 2011-12; FDIC FIL 22-2017) as well as the April 9, 2021, Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance. This guidance relates to systems or models used […]
The Bank Secrecy Act/Anti-Money Laundering area of compliance is always evolving. As an example, we are currently transitioning the name of this specialized area of compliance from Bank Secrecy Act (BSA) to Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) to coincide with the term’s examiners are now using within their documents and reports. […]
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help […]
Although there have been few new or changed regulations related to Deposit Compliance, missteps in compliance with these regulations can cause consumer harm. It’s important to stay focused and make sure staff changes or the implementation of new systems don’t increase errors at your institution. Helping institutions identify errors in deposit operations is a routine […]
On December 20, 2023 the FDIC approved and issued a final rule regarding changes to 12 CFR 328: rules for the use of FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentations of Insured Status, and Misuse of the FDIC’s Name or Logo. The updated rules are effective April 1, 2024, with a mandatory compliance […]
Below is a link to the Regulatory Updates as of the end of Q4. 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 […]