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
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 […]
