Delivering the advice and expertise to measure, control, and manage lending-related consumer risk.
We ensure that your lending policies and procedures are satisfactory and keep you informed on staying on the right side of regulators.
No bank wants to emerge from an exam of its lending practices only to have regulators issue an MOU or something worse.
TCA makes sure that that doesn't happen to you.
Our team, all former bankers, has decades of experience conducting consumer compliance audits and helping banks adhere to the many alphabet lending regulations.
We know that the alphabet regs aren't perfectly designed: While complying with one, you may violate another. And we're also aware of how intense – and yes, often tedious – the audit process can get.
Still, it's an essential step to make sure you're serving and protecting your customers and not jeopardizing your bank.
We're here to ease the pressure on your team and serve as your third line of defense.
Our exhaustive scoping discussion gives us an in-depth understanding of your products and services, the policies and procedures you have in place, and your reasons for conducting business in a particular way.
Based on our findings, we develop an appropriate roadmap for our audit.
You can count on us to thoroughly review your policies to ensure they're adequate for the size and complexity of your bank and conduct transaction testing to verify your practices align with regulatory requirements and your stated policies and procedures.
Given that we do such audits daily, we quickly spot the discrepancies that give examiners pause and develop appropriate strategies for correcting and mitigating issues before an examiner finds and flags them.
Central to a sound CMS and receiving a satisfactory compliance exam are having an independent audit firm like ours catch problems, provide guidance on mitigating them, and retest before examiners arrive.
TCA provides A Better Way to reduce your lending-related consumer risk.
Key deliverables include:
- Bringing a seasoned perspective to auditing your lending practices
- Ensuring that your policies and procedures align with regulatory requirements
- Ensuring required disclosures and notices you provide to borrowers meet regulatory requirements
- Providing insight on hot topics and current pressure points from a regulatory point of view
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 …
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 …
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 …
New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections Read More »