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
New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase […]
Regulatory Updates – Third Quarter 2022
Below is a link to the Regulatory Updates as of the end of Q3. 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 […]
Do you Remember? HMDA – Reporting Open-End Lines of Credit
It’s time for a trip into the Way-Back Machine, all the way back to April 16, 2020, when the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C. This amendment permanently raised the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years. The […]
Renewed Focus on Overdraft and “Junk” fees
One of the consequences of shrinking interest rates and interest margins is that financial institutions’ reliance on non-interest income has significantly increased over the last decade. The Consumer Financial Protection Bureau (CFPB) published an initiative on January 26, 2022 stating its intention to research the impact of fees on American consumers. The press release specifically […]
B Prepared for Compliance in Commercial Lending
It’s common for many lenders to believe that commercial lending is exempt from federal compliance regulations. However, this would be untrue – commercial loans are subject to the following compliance regulations: Regulation C/HMDA, Flood Disaster Protection Act, and Regulation B/ECOA. This article will focus on only one the regulations above – Regulation B. Under this […]
2022 Census Tracts Changes What it May Mean for Your Assessment Area
The 2020 Census data has been released by the US Census – and it may impact your Assessment Area for CRA and your Lending Area for Fair Lending. The Federal Financial Institutions Examination Council (FFIEC) which provides uniformity and consistency in the supervision of financial institutions, incorporates the US Census data in a format that […]
