Specialties
Deposit Regulations
Overdraft Protection Program 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
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 […]
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 […]
