Loan Servicing and Loan Operation Reviews
Policy and Procedure Reviews
Overdraft Protection Program Review
TCPA and COPPA Reviews
Retail Sales, NDIP Reviews
Regulation O Review
Delivering Support that Mitigates Risk, Services Customers, and Protects Your Reputation
We provide knowledge, experience, and guidance that allow your bank to adhere to consumer protection laws and manage their complexities.
Consumer compliance professionals face a daunting task trying to stay up on the changing consumer compliance landscape and fully understanding the implications that every regulatory change has on your bank.
That's where we come in.
We've spent decades building our expertise in this complex and often conflicting area of compliance. That experience has given us a ringside seat on how banks find themselves in regulatory trouble.
Whatever your challenge, we've likely seen something similar, and we have the expertise to review all applicable federal consumer regulations, from Regulation B to Regulation Z.
Still, we know that each bank is unique.
That’s why we start each engagement by gaining a 360-degree view of your bank operations and culture before conducting any audits, reviews, and testing.
This initial process allows us to understand your unique risk, pinpoint areas of concern, and recommend an appropriate review scope. Our approach helps you mitigate your risk and prepare for your next regulatory exam.
We also enhance your compliance culture by providing sensible recommendations and best practices throughout the process to help you put corrective action in place.
After all, protecting and serving your customers are crucial to building your community's trust, maintaining your reputation, and strengthening your bank.
TCA provides A Better Way to manage your consumer compliance obligations.
Key Deliverables Include:
- Lending, Loan Origination, and Loan Servicing – Review practices, policies, and procedures to measure, control, and minimize lending-related consumer risk.
- Deposit-related regulations and statutes – Review practices, policies, and procedures to measure, control, and minimize deposit-related consumer risk.
- Home Mortgage Disclosure Act (HMDA) – Ensure the data reported on your loan application register (LAR) is accurate prior to the required filing date.
- Compliance Management System (CMS) – Ensure that your CMS reflects your current risk and meets regulatory expectations for board and management oversight, effective monitoring and audit schedules, and policies and procedures to mitigate consumer harm.
Consumer Compliance Insights
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 …
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A Refresh on Regulation B’s Special Purpose Credit Program
On April 26, 2022, Wolters Kluwer conducted a webinar “Special Purpose Credit Programs: Everything You Always Wanted to Know”. The speakers included: Patrice Ficklin, Fair Lending Director of the Consumer Financial Protection Bureau Pamela Perry, Vice President, Single-Family Equitable Housing, Freddie Mac Kenneth Scott, Citibank Anand Raman, Skadden Arps The speakers discussed the credit needs …
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Regulatory Updates – Second Quarter 2022
Below is a link to the Regulatory Updates as of the end of Q2. 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 …
Identifying Higher Risk Customers using Keyword Searches
Financial institutions are facing increased regulatory pressure on Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures, particularly regarding inherently higher-risk customer types. CDD is critical to identifying and monitoring customers involved in higher-risk activities. Identification of higher-risk customers starts at account opening and your account opening procedures should incorporate this due diligence. Some …
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