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
Combating Elder Financial Exploitation
On August 30, 2017, FinCEN issued a memorandum titled “Memorandum on Financial Institution and Law Enforcement Efforts to Combat Elder Financial Exploitation.” Elder Financial Exploitation is the improper use of an older person’s funds or assets. Assets can also include the older person’s property or belongings. When an older person is being exploited, it often […]
What is the Cloud?
It’s not atmospheric, but the term is banner‐like: sky-borne and all powerful. Before we can discuss the hot topic of shared multi-tenant environment risk in our next article, we need to take a step back and address, “What is Cloud Computing?” Sure, the cloud is out there, somewhere in the unknown, or most likely hidden […]
Last‐minute 2018 HMDA Clarifications
The long-awaited deadline to begin collecting 2018 HMDA data is here! Banking agencies have issued HMDA guidelines on data testing and additional information on HMDA data collection. Also, the Consumer Financial Protection Bureau (CFPB) has clarified some interpretations as it has worked through numerous questions via phone calls and emails from filers. One of the […]
Never Too Much BSA Training
With new leadership at the CFPB, OCC and FDIC, one may put training expenditures on the back burner thinking regulatory relief may make training not an every‐year mandate. Until you see relief in a regulation or rule change, don’t make any assumptions because training exceptions are BSA Pillar violations. Remember, a pillar violation can trigger […]
Video Gambling: A Good Bet for Your BSA Program?
Following the recession of the last decade, many states explored creative options to generate additional revenue without increasing income or sales taxes. Given the popularity of lotteries, some states – including Illinois, South Dakota, West Virginia, and Oregon – legalized video gambling machines. State governments, local municipalities, machine operators and business owners all share in […]
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