David Mulkerin

The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds, which are tied to the Consumer Price Index, for Regulation Z and Regulation M exemptions. Loans or leases at or below the thresholds are subject to regulatory protections. The regulators have released the new index limit for

On October 25, 2018, the FFIEC released the public disclosures for CRA data submitted for the calendar year 2017. Institutions that report CRA data should go to the FFIEC website and download their disclosure tables for availability on request. The report should be made a part of your CRA Public File within three business days

Various regulatory agencies have released resources over the past couple weeks. As part of being a compliance partner and showing clients A Better Way with TCA, please see the following key insights. Appraisal FAQ Released On October 16, 2018, the OCC, FDIC and FRB released a joint Frequently Asked Questions document in response to comments

The NMLS Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies will be able to complete their annual attestation that the company’s record is up to date, pay their NMLS processing

As we all well know, S.2155 provided some anticipated regulatory relief covering many areas. One of the relief items was HMDA relief, which TCA covered in a previous special release. As a quick refresher, the Act provides that an institution does not need to report data with respect to closed‐end mortgage loans if it originated

Based on the Consumer Price Index in effect on June 1, 2018, which increased 2.5%, the Consumer Financial Protection Bureau (CFPB) released a number of new threshold amounts which go into effect on January 1, 2019. They include:  The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged in

Hot on the heels of the release of the HMDA data tables for 2017, the CFPB/BCFP has released its tool for validity checking the correctness of your Institution’s HMDA file for the calendar year 2018 data being submitted in 2019. You can find this tool at https://ffiec.cfpb.gov/tools/file‐format‐verification. The tool does exactly what it says: verifies

The CFPB has released the public disclosures for HMDA data submitted for calendar year 2017. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As the tables are no longer required to be made a part of your CRA Public File, you can

On April 3, 2018, FinCEN issued a frequently asked questions (FAQ) document, FIN‐2018‐G001, discussing the Beneficial Ownership Rules which go into effect on May 11, 2018. The FAQ addresses the following topics, among others: Beneficial Ownership Threshold Interaction of the beneficial ownership threshold with other AML program obligations Collection of beneficial ownership information for direct