Helping your team shape policies and procedures to strengthen your lending operations and allow you to withstand regulators' scrutiny
We perform exhaustive reviews to discover whether you're appropriately controlling and minimizing consumer lending risk.
Compliance in the consumer lending arena continues to get more complicated. Regulators have high expectations and there's an overflow of guidance from various federal agencies: CFPB, FDIC, OCC, and others. Plus, consumers have gotten savvier about their rights.
It's helpful to have a competent team to walk alongside you, ensuring that your lending policies are fair, that your loan servicing strategy is effective, and that you can measure, control, and minimize lending-related consumer risk and avoid consumer harm.
Numerous banks have placed their trust and confidence in TCA. Our team members, all former bankers, have real-life experience managing day-to-day consumer and mortgage lending compliance and preparing for regulatory exams.
We tap that deep expertise when we assess your loans, operations, and policies with the same scrutiny as examiners.
Our review includes:
- Looking at the consumer loan and mortgage documentation, checking for correct disclosures, borrowers' payments, and loan modifications.
- Ensuring that your written policies, procedures, products, and operations are current and reflect your agreement with borrowers.
- Identifying flood insurance coverage gaps.
- Evaluating your training and recommending changes, where necessary.
- Testing whether your procedures are adequate to minimize your risk.
Working with the TCA team is an investment in your future. Besides preparing for your exam, we advise you on modifications you can make to align your policies and procedures with your current needs and longer-term goals.
TCA's A Better Way for loan servicing and operations gives you the how-to on addressing your consumer lending risk.
Key deliverables include:
- Identifying compliance deficiencies and recommending corrections to help you pass future exams more easily
- Checking that you're complying with all relevant consumer and mortgage lending regulations
- Evaluating staff competence and training
Additional Compliance Topics
HOEPA VS HPML (High-Cost and Higher Priced Mortgage Loan)
The Home Ownership and Equity Protection Act (HOEPA) was enacted in 1994 as an amendment to the Truth-in-Lending Act (TILA) to address abusive practices in refinances and closed-end home equity loans with high interest rates or high fees. Higher Priced Mortgage Loans (HPML) were implemented as part of the Mortgage Disclosure Improvement Act in 2009 […]
Tips for a Successful Offsite Review
The saying goes that the only constant is change, which is true. In this post-pandemic environment, TCA continues to complete most engagements remotely. Technology advancements have made the process easier, but offsite engagements create different challenges. Please take a moment to review some tips for an efficient, effective TCA remote review. Ensuring a Successful Remote […]
Regulatory Updates – First Quarter 2024
Below is a link to the Regulatory Updates as of the end of Q1 2024. 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 […]
AML/CFT Transaction Monitoring – Importance of Tuning Your AMS Model
Regulators expect compliance with the standards established in the model risk management guidance (MRMG) (Federal Reserve SR Letter 11-7, OCC Bulletin 2011-12; FDIC FIL 22-2017) as well as the April 9, 2021, Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance. This guidance relates to systems or models used […]
TCA’s Top 5 BSA/AML Concerns
The Bank Secrecy Act/Anti-Money Laundering area of compliance is always evolving. As an example, we are currently transitioning the name of this specialized area of compliance from Bank Secrecy Act (BSA) to Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) to coincide with the term’s examiners are now using within their documents and reports. […]
Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs
Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA provides A Better Way to help […]
