Loan Servicing and Loan Operation Reviews
Policy and Procedure Reviews
HMDA & CRA Data Integrity Reviews
Overdraft Protection Program Review
TCPA and COPPA Reviews
Retail Sales, NDIP Reviews
Regulation O 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
FDIC Insurance – Communication is Key
Because of the recent Bank failures, your customers may feel skittish today. Although the news pundits all are saying deposit accounts are insured up to $250,000, we know this may not be the case. Consider having Management craft a statement message or online banking alert assuring customers their funds are insured. You should also ensure …
FDIC Name Change – Updated
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance …
Regulatory Updates – Fourth Quarter 2022
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 …
HMDA News and Census Tract Updates
Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated …
CRA Asset-size Thresholds Announced for 2023
The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. …
HMDA and HPML Thresholds Bumped Up for 2023
On December 28, 2022, 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 …