Helping you address the regulatory requirements associated with your Adjustable Rate Mortgages (ARMs)
We review your ARM documents and servicing practices, paying particular attention to routine errors that examiners focus on.
Given that interest rates have been low in recent years and fewer consumers likely have opted for ARMs, it would be normal if your staff’s proficiency in addressing all the compliance steps were a tad rusty.
Ours isn’t.
Reviewing ARM documents has always been a routine part of our business, and our team has remained up to date in all the regulatory requirements.
As such, we understand the latest changes and their impact on your operations.
Our team thoroughly reviews your portfolio of ARM loans to be sure that you comply with all the related regulations, including TRID, Reg X, and Reg Z.
We cover all the basics, like the timing, content, and terms of your rate adjustment notices and disclosures for every one of your ARM products.
We also dig deeper to identify the errors that bank examiners encounter most, whether they’re disclosure trip-ups, miscalculations, input mistakes, using an inappropriate or stale index, or incorrect principal loan balances.
We show you how to correct mistakes and implement a system to eliminate future errors.
Often, we also recommend and deliver training for mortgage servicing personnel.
Count on TCA’s A Better Way to ensure that your ARM compliance procedures are up to date and reflect the risks of your product line.
Key deliverables include:
- Assessing your compliance with Reg X and Reg Z
- Reviewing your method for providing rate change notices to ARM loan customers
- Recommending training or refreshers for mortgage servicing staff
- Ensuring your policies and practices address the risks associated with your suite of ARM products
Additional Compliance Topics
FDIC Name Change – Updated, Again
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 […]
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 […]
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 […]
