Ensuring Your Deposit Operations Meet Regulatory Standards
We provide your institution with clear, actionable insights to maintain compliance, reduce risk, and enhance consumer confidence.
Risks are inherent in all areas of banking, including deposit operations. Providing clear and compliant disclosures at account opening is crucial to help consumers understand the features of their accounts. However, maintaining compliance with the myriad of deposit regulations can be complex and time-consuming.
That's where TCA Compliance steps in. We offer comprehensive reviews of your deposit-related practices, policies, and procedures to ensure adherence to applicable regulations and to mitigate potential risks.
Our Approach
Our experienced consultants conduct thorough evaluations of your institution's deposit operations, focusing on key regulatory areas, including:
Regulation E – Electronic Funds Transfer
- Assessment of initial account opening disclosures.
- Review of subsequent disclosures and changes in terms.
- Evaluation of information displayed at ATMs, on receipts, and periodic statements.
- Verification of annual error notice compliance.
Regulation E – Error Resolution
- Examination of error resolution processes and procedures.
- Transaction testing for ATM, ACH, and POS transactions.
- Validation of timely notifications for provisional and final credits.
- Review of communications for denied claims.
Regulation E – Overdraft Opt-In Procedures
- Analysis of opt-in procedures for compliance with regulatory requirements.
Regulation E – Gift Card Rules
- Review of gift card issuance and disclosure practices.
Regulation E – Foreign Remittances
- Determination of applicability.
- Evaluation of disclosure notice requirements and timing.
- Assessment of prepayment and receipt disclosures.
- Review of remittance error handling and testing procedures.
Regulation CC – Funds Availability
- Validation of disclosure contents and applicability.
- Assessment of account hold procedures and notice timing.
- Transaction testing for account holds.
Regulation DD – Truth in Savings
- Verification of initial account opening disclosures.
- Review of interest payment methods and minimum balance requirements.
- Analysis of assessed fees and triggering circumstances.
- Evaluation of time deposit rules, bonus requirements, and overdraft disclosures.
- Review of fee schedules for accuracy and compliance.
Periodic Statements
- Validation of Annual Percentage Yield (APY) disclosures.
- Verification of interest payment accuracy.
FCRA Deposit Adverse Action Notice
- Assessment of notice accuracy and timely delivery.
Official Signage
- Verification of the presence and accuracy of required official signage at main and branch offices.
TCA's A Better Way for deposit regulations ensures your institution meets compliance standards with clarity and confidence, reducing risks in every aspect of deposit operations.
Key deliverables include:
- A comprehensive review of all deposit-related disclosures and procedures.
- Identification of compliance gaps and regulatory risks.
- Practical recommendations for improving compliance.
- Detailed compliance report with prioritized action items.
Additional Compliance Topics
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 2 of a 3 Part Series In our last article, TCA recapped items necessary for origination and proper disclosure of ARM Loans. In this second article, we will review the requirements for complying with underwriting requirements unique to Adjustable-Rate Mortgages. Underwriting ARM Loans While banks are required to comply with the Ability-to-Repay standards in […]
Regulatory Updates – Second Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q2. 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 […]
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 1 of a 3 Part Series For many years, we have experienced a low interest rate environment and originated predominantly fixed rate mortgages. Well times are changing – with the increase in interest rates, the popularity of Adjustable-Rate Mortgages is gaining momentum. We might be a little “rusty” in the process of originating and […]
FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion
The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating […]
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 […]
Regulatory Updates – First Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q1. 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 […]
